Mail Stop 6010


      May 24, 2005


Via U.S. Mail and Facsimile to (651) 638-0477

Scott P. Youngstrom
Chief Financial Officer
Compex Technologies, Inc.
1811 Old Highway 8
New Brighton, MN 55112


	Re:	Compex Technologies, Inc.
		Form 10-K for Fiscal Year Ended June 30, 2004
		Filed September 28, 2004
Forms 10-Q for Fiscal Quarters ended September 30, 2004, and
December
31, 2004
      File No. 000-09407

Dear Mr. Youngstrom,

      We have reviewed your response letter dated March 23, 2005
and
have the following additional comments.  We have limited our
review
to only your financial statements and related disclosures and do
not
intend to expand our review to other portions of your documents.
In
some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.  After reviewing this
information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.



Form 10-K for the Fiscal Year Ended June 30, 2004

1. Summary of Significant Accounting Policies - Page 34

Revenue Recognition and Provisions for Credit Allowances and
Returns
- - Page 34

1. Refer to your response to previous Comment 3.  For the sales of
medical products in the United States, you disclose that you
establish a reserve for sales allowances, product returns and
rental
credits at the of time revenue recognition.  However, you
indicated
that "for patient returns of products after purchase, the amount
previously recorded as revenue in a prior period is provided for
by
reducing gross revenue in the current period."  Tell us why
returns
are not applied against the reserve established at sale.  Clarify
the
basis for the accounting supplementally.

2. For international sales of products to heath care providers you
identify that revenue is recognized at the time of shipment or
upon
notification from a health care provider that the equipment has
been
prescribed and provided to the patient. Tell us more about the
arrangements with the health care providers. Do you have
consignment
contracts with them? How do you determine whether to recognize
revenue upon shipment to the provider or upon prescription to the
patient? Please also clarify the disclosure in future filings.

*	*	*	*

	As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information. Please file your
cover letter on EDGAR.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

	You may contact Kevin Kuhar, Staff Accountant at (202) 551-
3662
or me at (202) 551-3605 regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Angela Crane, Branch Chief, at (202) 551-3554.


      								  Sincerely,


								  Gary Todd
								  Reviewing Accountant
Mr. Scott P. Youngstrom
Compex Technologies, Inc.
May 24, 2005
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