Mail Stop 0306


May 2, 2005






Mr. Kevin T. Lusardi
Vice President and Chief Financial Officer
Milestone Scientific Inc.
220 South Orange Avenue
Livingston Corporate Park
Livingston, NJ 07039

	RE:	Milestone Scientific Inc.
		Form 10-KSB for the fiscal year ended December 31, 2004
		File No. 1-14053

Dear Mr. Lusardi:

      We have reviewed your filing and have the following
comments.
We have limited our review to matters related to the issues raised
in
our comments.  Where indicated, we think you should revise your
document in future 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

Notes to Consolidated Financial Statements - Page F-8

Note B-8. Revenue Recognition - Page F-9
1. We note that "revenue is recognized net of discounts and
allowances when title passes at the time of shipment and
collectibility is reasonably assured and the company has no
further
performance obligations."  Do post-shipment obligations, such as
installation, set-up or customer acceptance, affect the timing of
revenue recognition? Describe the significant terms of your
agreements with independent sales representatives, including
payment,
price protection, return, exchange, and other significant matters.
Explain and support when you believe it is appropriate to
recognize
revenue to independent sales representatives. Refer to SAB 104 and
SFAS 48 as necessary.

2. Supplementally tell us more about the purchase and pricing
options
available to your customers.  Do contracts set forth fixed prices
for
purchases of products?  Do these prices change over time?  If so,
how
are changes in prices over the term of the contracts, if any,
accounted for?   Do prices charged vary between customers?  Do you
offer discounts?  Consider SAB 104 when drafting your response as
applicable.

3. In this regard, we note you implemented a sales program in the
first quarter of 2005 which you will provide a one year supply of
hand pieces free to customer that purchase a CompuDent unit.
Supplementally tell us how you are accounting for this program.
Confirm that you are classifying the expense of the free
disposables
in cost of sales.  Refer to EITF 00-22 in your response.

4. Tell us how warranty costs are estimated at the time of
shipment.
If material, revise future filings comply with the disclosure
requirements of paragraph 14 of FASB Interpretation No. 45.

Note I. Stockholder`s Equity - Page F-13

5. In each transaction involving the issuance of warrants, please
tell us and expand your disclosures in future filings to explain
how
each issuance was valued.  Address both the method and the
significant assumptions applied.




*    *    *    *


	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.

      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.

      You may contact Dennis Hult, Staff Accountant, at (202) 942-
2812 or myself if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
942-1931 with any other questions.

							Sincerely,


							Angela J. Crane
							Branch Chief
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Kevin T. Lusardi
Milestone Scientific Inc.
May 2, 2005
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