Utah Medical Products, Inc. Correspondence September 6, 2005

September 6, 2005

Kate Tillan

Assistant Chief Accountant/ Mail Stop 03-06

Division of Corporation Finance

U.S. Securities and Exchange Commission

Washington, D.C. 20549-0306

VIA EDGAR

Re: Utah Medical Products, Inc.

File No. 001-12575

Confidential Treatment Request - Correspondence dated September 6, 2005

Dear Ms. Tillan:

Utah Medical Products, Inc. (UTMD) respectfully requests that the portion identified below of our response to SEC comments dated August 31, 2005 be afforded confidential treatment under SEC Rule 83 (17 CFR 200.83). We request that the redacted portion of our response not be disclosed publicly, including in response to a request under the Freedom of Information Act.

We have prepared the attached correspondence in compliance with rules relating to confidential treatment requests. The portion redacted is:

o	The table portion of UTMD’s response to Item 2, starting on line 71 of page UTSF 0002.

We are separately mailing to your attention an un-redacted hard copy of our response, highlighting the portion that has been redacted.

We appreciate your help in this important matter. Please contact me at 801-569-4015 if you are not able to comply with this request for any reason, or if you have questions.

Sincerely,

/s/ Greg A. LeClaire

Greg A. LeClaire

CFO

UTSF 0001

Confidential Treatment Requested by Greg A. LeClaire

5 September 6, 2005

7 Ms. Kate Tillan

8 Assistant Chief Accountant

9 Mail Stop 6010

10 Division of Corporation Finance

11 U.S. Securities and Exchange Commission

12 Washington, D.C. 20549-6010

14 VIA EDGAR

16 Re: Utah Medical Products, Inc. (UTMD)

17 Form 10-K/A for the Fiscal Year Ended December 31, 2004

18 Filed July 19, 2005

19 Form 10-Q/A for the Fiscal Quarter Ended March 31, 2005

20 Form 10-Q for the Fiscal Quarter Ended June 30, 2005

21 File No. 001-12575

23 Dear Ms. Tillan:

24 Thank you for your continued dialogue regarding the above filings. This letter is UTMD’s response to SEC

25 written comments dated August 31, 2005, which will also be filed on EDGAR as private correspondence with

26 the SEC. For ease of reference in the following, I have incorporated the August 31, 2005 comments in italics

27 followed by UTMD’s responses.

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

29 Consolidated Financial Statements, page F-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.

36 UTMD Response to Item 1.:

37 Pursuant to the September 1, 2005 teleconference with you, Greg LeClaire explained that UTMD and its

38 auditors continue to believe that its Form 10/K/A for the fiscal year ended December 31, 2004 does not

39 constitute a restatement and appreciates the SEC’s decision to back-off its requirement for UTMD to file

40 another amendment to label these financial statements as restated. UTMD further understands that the SEC is

41 not requesting UTMD’s 2004 financial statements to be labeled as restated in subsequent filings for this

42 particular December 31, 2004 Form 10/K/A filing. However, in future filings, if required by U.S. GAAP,

43 UTMD confirms that it will label its financial statements as restated and include a footnote describing the nature

44 and amount of the restatement if UTMD has a correction of an error constituting a U.S. GAAP-defined

45 restatement.

UTSF 0002

Confidential Treatment Requested by Greg A. LeClaire

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

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.

56 UTMD Response to Item 2.:

57 The nature of the prepay obligations is that certain foreign customers make a fixed commitment, in writing, to

58 purchase goods from UTMD to be shipped as of a certain date. The terms of these contracts require the

59 customer to pay in advance of UTMD shipping the product. If the customer has not made the required

60 prepayment by the scheduled shipment date, UTMD contacts the customer to determine if the customer has any

61 intention of violating the contract terms by not making the required prepayment. Under this circumstance,

62 UTMD would not recognize revenue. However, occasionally, a foreign customer under a prepay obligation will

63 request UTMD to bill completed products according to the contract, but hold shipment until payment will be

64 made. UTMD believes this complies with the criteria of SAB Topic 13.A 3(a) as described in our response to

65 prior comment 6 in your August 10, 2005 letter. However, due to the historically infrequent and immaterial

66 nature (see table below), UTMD will no longer recognize revenue under bill and hold foreign prepayment

67 arrangements.

69 Table of “Bill and Hold” Prepayment Sales

71 [*********The table portion of UTMD’s response to Item 2 is redacted***************]

73 Note 5. Note Payable, page F-18

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.

80 UTMD Response to Item 3.:

81 Thank you for your comment. UTMD will disclose its principal financial loan covenants in its notes to

82 financial statements in accordance with item 10(e)(1)(ii) of Regulation S-K.

84 I trust that UTMD’s responses are now complete to the satisfaction of the SEC. Thank you for your review and

85 assistance.

87 Sincerely,

88 /s/ Greg A. LeClaire

89 Greg A. LeClaire

90 Chief Financial Officer