September 26, 2005

Via U.S. Mail

Timothy B. Hansen
Chief Executive Officer
Imaging Diagnostic Systems, Inc.
6531 NW 18th Court
Plantation, Florida 33313

RE:		Imaging Diagnostic Systems, Inc.
		Form 10-K for the Fiscal Year Ended June 30, 2005
		Form 10-Q/A for the Fiscal Quarter Ended March 31, 2005
		File No. 000-26028

Dear Mr. Hansen:

      We have limited our review of your Form 10-K for the fiscal
year ended June 30, 2005, and Form 10-Q/A for the fiscal quarter
ended March 31, 2005, to disclosures relating to your contacts
with
countries that have been identified as state sponsors of
terrorism,
and will make no further review of the Form 10-K and Form 10-Q/A.
Our review with respect to this issue does not preclude further
review by the Assistant Director group with respect to other
issues.
At this juncture, we are asking you to provide us with
supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. After
reviewing
this information, we may or may not 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.



General -

We note that on page 19 of Amendment No. 1 to your 10-Q for the
quarterly period ended March 31, 2005, filed on July 20, 2005, you
state that in March 2005 you announced that you signed
distribution
agreements for 20 territories, including Iran and Libya.  In light
of
the fact that Iran and Libya have been identified by the U.S.
State
Department as state sponsors of terrorism; Iran is subject to
economic sanctions administered by the U.S. Treasury Department`s
Office of Foreign Assets Control (OFAC); and Libya was until
September 21, 2004, subject to OFAC-administered sanctions, please
describe for us the extent and nature of your past, current, and
anticipated contacts with Iran and Libya; advise us of the
materiality to you of your contacts with Iran and Libya; and
advise
us of your view as to whether those contacts constitute, either
individually or in the aggregate, a material investment risk for
your
security holders.  In preparing your response please consider that
evaluations of materiality should not be based solely on
quantitative
factors, but should include consideration of all factors that a
reasonable investor would deem important in making an investment
decision, including the potential impact of corporate activities
upon
a company`s reputation and share value.  In this regard, we note
that
legislation requiring divestment from, or reporting of interests
in,
companies that do business with countries designated as state
sponsors of terrorism has been adopted by Arizona and Louisiana.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.


      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk


cc: 	Peggy Fisher
		Assistant Director
		Division of Corporation Finance