ABAXIS, INC.
                                3240 Whipple Road
                          Union City, California 94587

                                 March 31, 2006

Via Facsimile, UPS and EDGAR

Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
Securities and Exchange Commission
Mail Stop 6010
Washington, DC 20549

Re:      Abaxis, Inc.
         Form 10-K for Fiscal Year Ended March 31, 2005
         Filed June 14, 2005
         File No. 000-19720

Dear Mr. Rosenberg:

This correspondence is in response to the comment letter from the Staff of the
Securities and Exchange Commission (the "SEC") dated January 27, 2006, with
respect to Abaxis Inc.'s (the "Company") Form 10-K for the fiscal year ended
March 31, 2005. We are submitting this correspondence in conjunction with the
response letter to the Staff of even date herewith from DLA Piper Rudnick Gray
Cary US LLP, the Company's legal counsel, responding to the SEC's comments on
behalf of the Company and in accordance with Staff guidance provided in SEC
Press Release No. 2004-89 regarding submission of "Tandy" language.

         The Company hereby acknowledges the following:

         o   The Company is responsible for the adequacy and accuracy of the
             disclosure in the filings;

         o   The Staff's comments or changes to disclosure in response to the
             Staff's comments in the filings reviewed by the Staff do not
             foreclose the Securities and Exchange Commission from taking any
             action with respect to the filing; and

         o   The Company may not assert the Staff's comments as a defense in any
             proceeding initiated by the Securities and Exchange Commission or
             any person under the federal securities law of the United States.

If you should have any questions regarding the above, please do not hesitate to
contact me at (510) 675-6504.

Sincerely,

Abaxis, Inc.

By:     /s/ Alberto R. Santa Ines
        -------------------------
Name:   Alberto R. Santa Ines
Title:  Chief Financial Officer and Vice President of Finance

cc:     Ibolya Ignat, Securities and Exchange Commission
        Jim Atkinson, Securities and Exchange Commission
        Andrew D. Zeif, DLA Piper Rudnick Gray Cary US LLP