May 10, 2005



Mail Stop 03-06

Mr. Timothy C. Clayton
Chief Financial Officer
PPT Vision, Inc.
12988 Valley View Road
Eden Prairie, MN 55344


      Re:	PPT Vision, Inc.
Form 10-KSB for the Fiscal Year Ended October 31, 2004
Form 10-QSB for the Fiscal Quarter Ended January 31, 2005
		File No. 000-11518

Dear Mr. Clayton:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.



Form 10-QSB for the Fiscal Quarter Ended January 31, 2005

Item 3. Controls and Procedures - Page 17

(a) Evaluation of Disclosure Controls and Procedures

1. We note that your proposed revisions continue to qualify your
conclusion. Your conclusion should not be qualified and should
state
whether or not your disclosure controls and procedures were
effective
as of January 31, 2005. Please amend your Form 10-QSB as of
January
31, 2005, as previously requested, to state, in clear and
unqualified
language, the conclusions reached by your chief executive officer
and
your chief financial officer on the effectiveness of your
disclosure
controls and procedures. For example, if true, you can state that
your disclosure controls and procedures are effective including
consideration of the identified matters, so long as you provide
appropriate disclosure explaining how the disclosure controls and
procedures were determined to be effective in light of the
identified
matters.  Or, if true, you can state that given the identified
matters, your disclosure controls and procedures are not
effective.
You should not, however, state the conclusion in your current
disclosure, which appears to state that your disclosure controls
and
procedures are effective except to the extent they are not
effective.


* * * * *

       As appropriate, please amend your Form 10-QSB for the
Fiscal
Quarter Ended January 31, 2005 and respond to these comments
within
10 business days or tell us when you will provide us with a
response.
You may wish to provide us with marked copies of the amendments to
expedite our review.  Please furnish a cover letter with your
amendments 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 amendments and responses to our comments.

      You may contact Tom Dyer, Staff Accountant, at (202) 824-
5564
or me at (202) 942-2861 if you have any questions.  In this
regard,
do not hesitate to contact Michele Gohlke, Branch Chief, at (202)
942-7903.

							Sincerely,


							Kate Tillan
							Assistant Chief Accountant
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Mr. Timothy C. Clayton
PPT Vision, Inc.
May 10, 2005
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