Mail Stop 6010


      August 31, 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
August 23, 2005 and we have the following comments.  Where
indicated,
we think you should revise your documents in future filings 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

1. We note your response to prior comment 1 from our August 10,
2005
letter. As previously discussed, we believe that due to the
correction of an error in your previously issued financial
statements
that you should label your financial statements as restated and
include a footnote describing the nature and amount of the
restatement.  Please refer to paragraph 37 of APB 20.  As such,
please confirm that you will comply with U.S. GAAP in future
filings
if you have another restatement due to the correction of an error.

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

2. We note your response to prior comment 6 from our August 10,
2005
letter.  Please tell us the nature of the "prepay" obligation and
how
you evaluated all of the criteria related to revenue recognition
for
transactions where the customer is obligated to prepay you for
products.  If the customer is obligated to prepay for the
products,
explain why it is appropriate to recognize revenue prior to that
payment.  Within your discussion, tell us how you evaluated that
collectibility of these sales is reasonably assured.  Please also
provide to us the amount of revenue recognized in fiscal 2002,
2003,
2004 and the first six months of 2005 related to your transactions
with customers that are obligated to prepay for products when you
bill those customers.

Note 5. Note Payable, page F-18

3. We note your response to prior comment 7 from our August 10,
2005
letter.  While you should not include a non-GAAP measure within
your
financial statements under Item 10(e)(1(ii) of Regulation S-K, you
may disclose the nature of your principal financial loan covenants
in
the notes to your financial statements.  That is, you may disclose
the terms of the EBITDA loan covenant in the notes to your
financial
statements, but you should not include a calculation/presentation
of
the amount of EBITDA as of any particular date in the notes to the
financial statements.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter 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 31, 2005
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