Mail Stop 6010

      August 23, 2005

Mr. Hanan Eibushitz
RoboGroup T.E.K. LTD.
13 Hamelacha Street, Afek
Industrial Park, Rosh Ha` Ayin, 48091, Israel


Re:	RoboGroup T.E.K. LTD.
	Form 20-F for the year ended December 31, 2004
	Filed June 30, 2005
	File No. 0-19435

Dear Mr. Eibushitz:


      We have reviewed your response letter dated August 22, 2005
and
related filings and have the following comments.  We have limited
our
review of your filing to those issues we have addressed in our
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 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.


Form 20-F for the year ended December 31, 2004

Consolidated Financial Statements

Independent Auditor`s Report,  page F-2
1. We note your response to prior comment one in our letter dated
August 15, 2005 and the amendment filed to your Form 20-F.
However,
we do not see that you have filed currently dated Section 302 and
906
certifications with your amendment.  Accordingly, please amend
your
Form 20-F to include the required certifications.
2. Additionally, we have the following comments regarding the
reports
of other independent accountants filed under Rule 2-05 of
Regulation
S-X that were relied upon by your principal auditors:
a) The subsidiary reports do not appear to be audited in
accordance
with PCAOB Standards.  Subsidiary audit reports filed under Rule
2-05
of Regulation S-X must also refer to compliance with PCAOB
Standards.
b) Mock & Partners International does not appear to be registered
with the PCAOB.  Under Section 102 of the Sarbanes Oxley Act of
2002,
any audit firm that prepares, issues, or participates in the
preparation or issuance of an audit report with respect to an SEC
issuer must be registered with the PCAOB.
c) The audit of Eshed Robotec B.V., Amsterdam is in accordance
with
accounting principles generally accepted in the Netherlands.  One
of
the audit reports should clearly state who is responsible for
auditing the conversion of the financial statements from the
foreign
GAAP into Israeli GAAP used in the primary financial statements.
Additionally, the division of responsibility among the auditors
with
respect to the U.S. GAAP reconciliations pursuant to Item 17 of
Form
20-F should be explicit in the audit reports.
Please amend your Form 20-F to address the above concerns.  We
refer
you to the International Reporting and Disclosure Issues in the
Division of Corporation Finance dated November 1, 2004, which can
be
found on www.sec.gov.
3. We note that you did not include the representations requested
in
our letter dated August 15, 2005.  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.

      As appropriate, please amend your filing 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 amendment to expedite our review.  Please furnish a cover
letter
with your amendment 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 amendment and responses to our
comments.

	You may contact Kristin Lochhead at (202) 551-3664 or me at
(202) 551-3671 if you have questions.


Sincerely,



Martin F. James
							Senior Assistant Chief
Accountant
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Mr. Eibushitz
RoboGroup T.E.K. LTD.
August 23, 2005
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