UNITED STATES

                       SECURITIES AND EXCHANGE COMMISSION

                             WASHINGTON, D.C. 20549

                               FORM CORRESPONDENCE


     PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934



                               September 24, 2004
                               ------------------
                      (Date of the earliest event reported)



                             Simulations Plus, Inc.
                             ----------------------
             (Exact name of Registrant as specified in its charter)


          California                                            95-4595609
          ----------                                            ----------
(State or other jurisdiction                                 (I.R.S. Employer
        of incorporation)                                   Identification No.)

                                     1-32046
                                     -------
                            (Commission File Number)

                 1220 West Avenue J, Lancaster, California 93534
                 -----------------------------------------------
                    (Address of principal executive offices)
                                   (Zip Code)

                                 (661) 723-7723
                                 --------------
               Registrant's telephone number, including area code





SUPPLIMENTAL RESPONSE TO COMMISSIONERS



                               September 23, 2004



Security and Exchange Commission
Washington, D.C. 20549

Commissioners:

In response to your comments, Simulations Plus, Inc. acknowledges that;

         1.       Simulations Plus, Inc. is responsible for the adequacy and
                  accuracy of the disclosure in the filings;

         2.       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

         3.       Simulations Plus, Inc. 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.




                                             /s/ Momoko Beran
                                             --------------------------------
                                             Momoko Beran
                                             Chief Financial Officer