Mail Stop 0306

      April 25, 2005

VIA U.S. MAIL and FACSIMILE (702) 737-6900


Eric M. Polis
Treasurer and Principal Financial Officer
ASI Technology Corporation
980 American Pacific Drive, Suite 111
Henderson, Nevada  89014

	RE:	ASI Technology Corporation
		Form 10-KSB for the fiscal year ended December 31, 2004
		Filed March 30, 2005
		File No. 000-06428

Dear Mr. Polis:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents. Where indicated, we think you should revise your
filings
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  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 filing.
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-KSB for the Year Ended December 31, 2004

Financial Statements

Statements of Operations - Page F-3
1. Revise future filings to separately state on the face of the
financial statements the tax provisions or benefits associated
with
your discontinued operations. Please note that income or loss from
discontinued operations including the gain or loss from disposal
of
discontinued operations should be reported net of the related
taxes.
Refer to paragraph 43 of SFAS 144.

Note 2 - Summary of Significant Accounting Principles and Policies
- -
Page F-6
Revenue Recognition - Page F-7
2. For development contract revenues, tell us why you believe that
percentage-of-completion method of revenue recognition is
appropriate
in your circumstances. Describe the significant terms of a typical
arrangement in sufficient detail so that we can understand the
basis
for your policies. In addition, tell us the nature and extent of
any
post development contract support generally associated with your
arrangements and describe the criteria you evaluate in assessing
whether that post development contract support is significant.
Revise future filings, if material.

Note 3 - Plasma Antenna Technology - Page F-12
3. Supplementally and in future filings provide details of how the
gain on sale of discontinued operations was determined.

Note 4 - Investments Securities- Page F-15
4. Provide more details of the initial valuation of the securities
received in connection with the sale of the discontinued
operations
and circumstances that resulted in the significant impairment of
these securities in fiscal 2004. Was the initial valuation based
on
quoted market prices?

Note 11 - Going Concern
5. Revise future filings to provide more specific details of your
viable plan of operations that has the capability of removing the
threat to the continuation of the business as required by FRC
607.02.
This discussion should be specific with regard to the time frames,
funding needs and sources and other matters related to the
development of your products or technology. The impact if you are
not
successful with these efforts should also be addressed. Additional
disclosure should also be included in MD&A.
*    *    *    *

      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 with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

	In connection with responding to our comments, 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 in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; 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 filing or in
response to our comments on your filing.

	You may contact Patrick Enunwaonye, Staff Accountant, at
(202)
824-5529 or me at (202) 942-1791 if you have any questions

							Sincerely,



							Brian Cascio
							Accounting Branch Chief


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Mr. Polis
ASI Technology Corporation
April 25, 2005
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