Mail Stop 3561

      							September 28, 2005

David L. Adams
Sr. Vice-President, Finance and Chief Financial Officer
8150 Trans Canada Highway
Montreal, QC H4S1M5
Canada


	Re:	SR Telecom, Inc
      Form 20-F for Fiscal Year Ended December 31, 2004
		Filed May 2, 2005

		Form 6-K dated July 30, 2004
		Filed August 4, 2004
      File No. 000-50378

Dear Mr. Adams:

      We have previously reviewed and commented on your Form 20-F
and
understand from your subsequent correspondence that the company
intends on amending the Form 20-F in response to our comments in
the
near future.  Please note that we have also reviewed your Form 6-K
dated July 30, 2004 and have the following additional comment.

      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.


General

We note that in Exhibit 99.1 to your 6-K dated July 30, 2004, and
filed August 4, 2004, you state that for the three month period
ended
June 30, 2003, 29 percent of wireless revenue was attributable to
business from your customer Sudan Telecom Company; that for the
three
month period ended June 30, 2003, Sudan Telecom Company was
responsible for 25.8 percent of total consolidated revenue; and
that
for the six month period ended June 30, 2003, 15.4 percent of
total
consolidated revenue was geographically attributable to Sudan.

In light of the fact that Sudan has been identified by the U.S.
State
Department as a state sponsor of terrorism, and is subject to
economic sanctions administered by the U.S. Treasury Department`s
Office of Foreign Assets Control, please describe for us your
contacts with Sudan and/or entities in Sudan; their materiality to
you; and your view as to whether those contacts constitute 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 Arizona and Louisiana have
adopted legislation requiring divestment from, or reporting of
interests in, companies that do business with U.S.-designated
state
sponsors of terrorism.  We note also that Illinois, New Jersey and
Oregon have adopted legislation requiring divestment from, or
reporting of interests in, companies that do business with Sudan,
and
several other U.S. states recently have proposed similar
legislation.


*    *    *    *


      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response via EDGAR.  When filing your amendment to your Form 20-F,
you may wish to provide us with a marked copy of the amendment to
expedite our review.  Please furnish a cover letter with your
amendment that keys your responses to our comments on your Form
20-F
and provides the information requested above.  Detailed cover
letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

You may contact Nicole Holden, Staff Accountant, at (202) 551-3374
or
Kyle Moffatt, Accountant Branch Chief, at (202) 551-3836 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3810 with any other
questions.

								Sincerely,



								Larry Spirgel
								Assistant Director


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Mr. Adams
SR Telecom,Inc
September 28, 2005
Page 3



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE