March 24, 2005
Mail Stop 0305

Via U.S. Mail and Facsimile

Susan M. Atkins
Chief Financial Officer
Impreso, Inc.
652 Southwestern Boulevard
Coppell, Texas 80401

RE:	Impreso, Inc. (the "Company")
	Form 10-K for the fiscal year ended August 31, 2004
	File No. 000-29883

Dear Ms. Atkins:

Based upon an examination restricted solely to considerations of
the
Financial Statements, Management`s Discussion and Analysis, and
Selected Financial Data, the staff has the following comments on
the
above-referenced documents.  We think you should revise all future
filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comments are inapplicable
or
a revision is unnecessary.  Please be as detailed as necessary in
your response.  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.

Please respond to confirm that such comments will be complied
with,
or, if certain of the comments are deemed inappropriate by the
Company, advise the staff of the reason thereof.

Pursuant to Rule 101(a)(3) of Regulation S-T, your response should
be
submitted in electronic form, under the label "corresp" with a
copy
to the staff.  Please respond within ten (10) business days.



Form 10-K for the fiscal year ended August 31, 2004

Item 6.  Selected Financial Data, page14

1. To the extent that factors exist which may materially affect
the
comparability of the information reflected in the selected
financial
data, you should either briefly describe or cross-reference to a
discussion thereof.  In this regard, we note that you disclose in
your Form 8-K dated December 15, 2004 that earnings per share for
fiscal 2004 increased 58% partially due to a non-recurring event,
a
deferred tax benefit resulting from the sale of your California
building; however, no information has been disclosed with regard
this
non-recurring event.  Please revise future filings to include a
brief
description or cross-reference to a discussion of the deferred tax
benefit resulting from the sale of your California building and
any
other material factors which may affect the comparability of the
information presented in your table.  See Instruction 2 of Item
301
of Regulation S-K.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Critical Accounting Policies
Revenue Recognition, page15

2. You state that you record revenue related to TST sales at the
time
of shipment, and for accounts that are not reasonably assured of
collection, you reserve for such doubtful accounts based upon your
historical experience and management`s evaluation of existing
economic conditions.  However, it is unclear whether your
assessment
of collectibility is performed at the outset of the arrangement,
prior to revenue recognition.  In this regard, supplementally tell
us
when you assess collectibility and how your revenue recognition
policy complies with Staff Accounting Bulletin Topic 13.  Your
response should include, but not be limited to, a timeline of when
you reserve for doubtful accounts in relation to the related
revenue
recognition.  Also, expand your disclosure in MD&A and in the
notes
to your consolidated financial statements to clarify your revenue
recognition policy in future filings.

Inventories, page 16

3. We note that you record reductions to revenue when products are
returned.  In this regard, supplementally tell us, with a view
toward
expanded disclosure in future filings, the nature and significant
terms of your product return policy and explain how your revenue
recognition policy complies with paragraph 6 of FAS No. 48.  We
may
have further comment upon receipt of your response.

Results of Operations, page 17

4. We note that revenues related to two significant customers, IBM
and Staples which represent 11% and 19% of fiscal 2004 revenue,
respectively, are expected to significantly decrease in future
periods for the reasons described in the Business section of the
filing.  In this regard, please revise future filings to discuss
the
impact that (1) the termination of the Trademark Licensing
Agreement
with IBM and (2) the significant decrease in purchases by Staples
will have on your liquidity, capital resources, and results of
operations (i.e., net sales or revenues and income from continuing
operations).  Similarly, discuss the impact that the expected
decline
in continuous feed business forms (as described in the first
paragraph under the caption, Market Conditions of TST) will have
on
your operations.  In addition, supplementally tell us how these
events impacted your impairment analysis for long-lived assets and
clearly explain your significant assumptions and estimates used in
the analysis.  We may have further comments upon receipt of your
response.  See Item 303(a)(1) through (3) of Regulation S-K and
Section III.B.3 of FR-72.

Liquidity and Capital Resources, page 18

5. In future filings, please include a discussion and analysis of
known trends and uncertainties with regard to your liquidity and
capital resources and whether your past performance is indicative
of
your future performance.  Such items may include, but not be
limited
to, the effect of the loss of the significant customers, your
program
of reducing inventory levels (as described on page 7), the
issuance
of debt to finance leasehold improvements (Note 13), and the sale-
leaseback of the facility in California (Note 7).  See Section IV
of
FR-72.

6. We also note that net cash provided from operating activities
and
net cash used in financing activities have significantly increased
during the fiscal year ended August 31, 2004 as compared to prior
years presented on the statements of cash flows.  In this regard,
please revise future filings to include a balanced discussion of
cash
flows generated by operating, investing and financing activities.
Discuss the underlying reasons for significant changes and whether
you expect trends to continue in the future.  See Section 501.03.a
of
the Financial Reporting Codification and Section IV of FR-72.

7. Revise future filings to discuss liquidity on a long-term basis
in
accordance with Instruction 5 to Item 303(a) of Regulation S-K.
If
you have not identified any sources of long-term liquidity,
include a
statement to that effect.

8. Revise future filings to discuss planned capital expenditures
and
related financing sources necessary to maintain sales growth.
Your
discussion should include, but not be limited to, the capital
expenditures related to the start-up costs of Alexa Springs, Inc.
See Section 501.02 of the Financial Reporting Codification.

Item 7A - Quantitative and Qualitative Disclosures About Market
Risk,
page 20

9. Please revise future filings to present your quantitative
disclosures about market risk so that they are presented in one of
the suggested formats outlined in Item 305(a) of Regulation S-K.

Financial Statements

Consolidated Statements of Cash Flows, page F-7

10. We note your gross presentation of the provision for losses of
receivables separate from the increase (decrease) in trade
accounts
receivable within operating activities of your consolidated
statements of cash flows.  Further, we also note your gross
presentation of the provision on inventory as separate line item
from
increase (decrease) in inventory.  Presenting these items on a
gross
basis is appropriate based upon the guidance outlined in FAS No.
95;
however, it appears your application of this guidance is
inconsistent
between the periods presented.  For example, you present the
provision for losses of receivables net of write-offs of accounts
receivable in fiscal 2004 and 2003 while in fiscal 2002 it is
reflected on a gross basis, excluding any write-offs of accounts
receivable.  Similarly, we note your gross presentation of the
change
in inventory for both fiscal year 2004 and 2002; however, in
fiscal
2003, the change is presented net of the provision for loss on
inventory.  In this regard, revise future filings for such that
these
and other similar items are presented on a consistent basis to
provide comparability between periods.

Note 2.  Summary of Significant Accounting Policies
Revenue Recognition, page F-9

11. Please tell us and disclose in future filings your planned
revenue recognition policy for products and/or services to be sold
under your wholly owned subsidiary, Alexa Springs, Inc.

Commissions and Rebates, page F-10

12. We note that you have reclassified sales commissions and
advertising discounts to selling, general and administrative
expense
from cost of sales in your 2003 and 2002 consolidated statements
of
operations.  In this regard, supplementally tell us, with a view
toward expanded disclosure, the nature and significant terms of
the
sales commissions and the advertising discount arrangements
provided
to your customers and quantify each type of incentive for each
period
presented.  Explain why the sales commissions and advertising
discounts you provide to your customers is not recorded as a
reduction to revenue as prescribed in EITF No. 01-9 and the
reason(s)
why you believe your accounting treatment for such costs is
appropriate.  Also, tell us the relevant accounting literature
that
supports your accounting treatment.  We may have further comments
upon receipt of your response.

Consolidated Statements of Operations, page F-5
Other Expense (Income), page F-10

13. We note that other expense (income) includes gain on sale of
assets, and expenses associated with the sale of the California
buildings.  In this regard, please revise future filings, to
separately quantify and present the gain on sales of assets, and
expenses associated with the sale of the California buildings as
components of operating income for each period presented versus
non-
operating items.  See footnote 68 of Staff Accounting Bulletin
Topic
13.

Note 7.  TST`s Equipment Lease Agreements, page F-16

14. To the extent you have material operating leases, revise
future
filings to disclose the significant terms of the leases.  Your
disclosure(s) should address the following, where appropriate:

* Material lease agreements or arrangements.

* The essential provisions of material leases, including the
original
term, renewal periods, reasonably assured rent escalations, rent
holidays, contingent rent, rent concessions, leasehold improvement
incentives, and unusual provisions or conditions.

* The accounting policies for leases, including the treatment of
each
of the above components of lease agreements.

* The basis on which contingent rental payments are determined
with
specificity, not generality.


Note 8.  Commitments and Contingencies, page F-17

15. Please tell us and disclose in future filing, how the amounts
associated with the loss from fraudulently diverted funds was
recorded in your consolidated financial statements.  We may have
further comment upon receipt of your response.

Form 10-Q for the Quarterly Period Ended November 30, 2004

16. Comply with the comments on the Form 10-K for the year ended
August 31, 2004 as they apply to filings on Form 10-Q.

* * * * *

You may contact Jean Yu at (202) 824-5421 or Katherine Mathis at
(202) 942-1994 if you have questions regarding comments on the
financial statements and related matters.  Please contact the
undersigned at (202) 942-1936 with any other questions.


								Sincerely,


								Linda Cvrkel
								Branch Chief
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Susan M. Atkins
Impreso, Inc.
March 24, 2005
Page 1