Mail Stop 6010


      August 10, 2005


Mr. Greg A. LeClaire
Chief Financial Officer
Utah Medical Products, Inc.
7043 South 300 West
Midvale, UT  84047

	Re:	Utah Medical Products, Inc.
      Form 10-K/A for the Fiscal Year Ended December 31, 2004
      Filed July 19, 2005
      Form 10-Q/A for the Fiscal Quarter Ended March 31, 2005
      Form 10-Q for the Fiscal Quarter Ended June 30, 2005
      File No. 001-12575

Dear Mr. LeClaire:

      We have reviewed your filings and your response letter dated
July 19, 2005 and we have the following comments.  Where
indicated,
we think you should revise your documents 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 information so we may
better understand your disclosure.  After reviewing this
information,
we may 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.


Amendment No. 1 to Form 10-K for the Fiscal Year Ended December
31,
2004 filed on July 19, 2005

Consolidated Financial Statements, page F-1

Report of Independent Registered Public Accounting Firm, pages F-3
and F-5


1. We note that you restated your financial statements to
reclassify
the amounts related to your gain from the settlement of a patent
dispute from extraordinary income to other non-operating income
within your statement of income.  Please tell us why you did not
label the financial statements as restated, disclose the reasons
for
the revision in a note to the financial statements and provide the
other disclosures required by paragraph 37 of APB 20.  Please also
tell us why your auditors do not refer to the restatement in the
auditor`s report and dual date the report.


Consolidated Statement of Income and Comprehensive Income, page F-
8


2. We note from your response to prior comment 11 from our June
15,
2005 letter and your amendment that you reclassified $6,060,000 in
2004 and $24,884,000 in 2003 related to your gain from the
settlement
of the Tyco patent infringement from extraordinary income to other
non-operating income.  As previously noted and based upon your
disclosure and responses to our comments, since these patents
relate
to your operations these costs should be classified within
operating
income.  Accordingly, please amend your Form 10-K and subsequent
Forms 10-Q to classify the gain within operating income.


3. In addition, please tell us and amend the Form 10-K to include
a
discussion of the nature, timing and measurement of the gain from
the
patent infringement settlement in the notes to the consolidated
financial statements.



Note 1.  Summary of Significant Accounting Policies, page F-12

Revenue Recognition, page F-13


4. We note your response to prior comment 6 from our June 15, 2005
letter.  Since sales with terms of FOB destination should be
recognized as revenue when received by the customer upon transfer
of
title and not when the product is shipped, you should revise your
revenue recognition accounting policy with respect to these
transactions in future periods and restate your financial
statements
for prior periods to correct this error, if material.  Your
assessment of materiality should include each reporting period,
including 2002 and 2003, and you should perform your assessment on
both a quantitative and qualitative basis.  The quantitative
analysis
should consider each relevant quantitative measure, including
gross
profit, and not just the error as a percentage of sales.


5. We note your disclosure that you believe "...that revenue
should
be recognized at the time of shipment as title generally passes to
the customer at the time of shipment."  Please tell us and revise
to
disclose why you use the term generally.  Disclose when you record
revenue at the time of shipment when title has not transferred and
why this policy complies with U.S. GAAP.


6. We note your response to prior comment 6 from our June 15, 2005
letter.  Please tell us the amount of revenue recognized in fiscal
2002, 2003, 2004 and the first six months of 2005 related to bill
and
hold sales.  Please explain to us how you evaluated all of the
criteria related to revenue recognition for bill and hold sales
discussed in SAB Topic 13.A.3(a).  Please also address why you
believe it is appropriate to recognize revenue on transactions
with
customers that are obligated to prepay for products when you bill
those customers.  Address how this policy meets the criteria of
SAB
Topic 13.A.1, as well as 13.A.3(a).



Note 5. Note Payable, page F-18


7. Under Item 10(e)(1)(ii) of Regulation S-K, you should not
present
non-GAAP financial measures on the face of your financial
statements
prepared in accordance with GAAP or in the accompanying notes.  As
such, please amend to delete your presentation of non-GAAP
measures
for EBITDA for the years ended December 31, 2003 and 2004 in the
notes to your financial statements.


Representations


8. Please refer to prior comment 15 in our June 15, 2005 letter.
We
note your statement that "UTMD provided a qualified
acknowledgement
of the third bullet point..." and you "...believe that [the] SEC`s
comments could be material to UTMD`s defense in an enforcement
proceeding, and therefore cannot acknowledge the third bullet
point
as written."  Please note that you may not change, qualify or
condition the requested representations in this manner.  As
previously requested, please provide all three acknowledgements in
the form previously requested.


      As appropriate, please amend your December 31, 2004 Form 10-
K
and March 31, and June 30, 2005 Forms 10-Q 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 information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendments and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 filing;

* staff comments or changes to disclosure in response to staff
comments 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.

      You may contact Tara Harkins, Staff Accountant, at (202)
551-
3639 or me at (202) 551-3604 if you have any questions.  In this
regard, do not hesitate to contact Michele Gohlke, Accounting
Branch
Chief, at (202) 551-3327.



      							Sincerely,


      Kate Tillan
								Assistant Chief Accountant


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Greg A. LeClaire
Utah Medical Products, Inc.
August 10, 2005
Page 5