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<SEC-DOCUMENT>0000842023-06-000020.txt : 20061020
<SEC-HEADER>0000842023-06-000020.hdr.sgml : 20061020
<ACCEPTANCE-DATETIME>20060411155718
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000842023-06-000020
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20060411

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			TECHNE CORP /MN/
		CENTRAL INDEX KEY:			0000842023
		STANDARD INDUSTRIAL CLASSIFICATION:	BIOLOGICAL PRODUCTS (NO DIAGNOSTIC SUBSTANCES) [2836]
		IRS NUMBER:				411427402
		STATE OF INCORPORATION:			MN
		FISCAL YEAR END:			0630

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		614 MCKINLEY PL N E
		CITY:			MINNEAPOLIS
		STATE:			MN
		ZIP:			55413
		BUSINESS PHONE:		6123798854

	MAIL ADDRESS:	
		STREET 1:		614 MCKINLEY PLACE NE
		CITY:			MINNEAPOLIS
		STATE:			MN
		ZIP:			55413
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
April 11, 2006

Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
Securities and Exchange Commission
Division of Corporate Finance
Washington, DC  20549

Re:  Techne Corporation
     Form 10-K for the Year Ended June 30, 2005
     File No. 000-17272

Dear Mr. Rosenberg:

This letter is in further response to written comments received by us from
the Securities and Exchange Commission (SEC), dated February 28, 2006,
concerning our Form 10-K for the year ended June 30, 2005.  On March 8, 2006,
we submitted a response to the SEC regarding these comments.  The following
supplements our previous response and replies to additional oral comments
communicated by SEC Staff Accountant, Vanessa Robertson, to Techne
Corporation Chief Financial Officer, Greg Melsen, via a phone conversation on
Friday, March 31, 2006.


As outlined in our March 8, 2006 response, in correspondence from the Company
to the SEC dated November 10, 2004 and in our periodic disclosure of Critical
Accounting Policies, our manufacturing process for proteins and antibodies
has and may continue to produce quantities in excess of sales forecasted
within the following two-year period.  Large quantities of proteins and
antibodies are manufactured to meet expected customer requirements and due to
the efficiencies of manufacturing in such quantities.  We only assign a value
to protein and antibody inventories if they are expected to sell within a
two-year period.  Despite this methodology of inventory valuation, these
products have long-term value, have minimal risk of obsolescence and may
generate substantial future gross margins.

At the time many of these products are developed, there may be no market or a
very limited market for them because of the limited scientific knowledge of
their biological function and activity.  Subsequently, scientific interest
may increase appreciably as more research is conducted and published.  This
is a process that occurs over multiple years and, as a result, may lead to
significant increases in sales of these products.  Since we are on the
leading edge with the development and release of new proteins and antibodies
associated with those proteins, it is very difficult to predict whether a
market for them will ever develop.  Accordingly, we assign little or no value
to new products at the time of their initial release as we cannot estimate
sales beyond a two-year horizon.  However, if a market does develop in the
future, we assign a value to these products that effectively reverses the
previously recorded write-down.  This is the practice we have followed for
the past 20 years.

We have studied and understand SAB Topic 5 BB regarding Inventory Valuation
Allowances and the SEC Staff's position "that a write-down of inventory to
the lower of cost or market at the close of a fiscal period creates a new
cost basis that subsequently cannot be marked-up based on changes in
underlying facts and circumstances."  This interpretive position, Opinion 20
and ARB 43, Chapter 4, Statement 5 collectively served as guidance when we
established our policies regarding the valuation of inventories, specifically
those related to our biotechnology protein and antibody inventories.  We also
review and consider these pronouncements and interpretations each reporting
period as we value these inventories and report our financial results and
disclosures.

We agree that SAB Topic 5 BB indicates that a write-down of the inventory
cost should not be reversed. As noted in our March 8, 2006 letter we have
evaluated our accounting policy and have concluded that its consistent
application results in the "write-up" of previously unvalued inventory which
quantitatively and qualitatively are not material to the Company's results of
operations, financial position, assets and stockholders' equity.  We will
continue to monitor the materiality of this accounting policy on an ongoing
basis.

Cost of Sales for Manufacturing and Inventory Changes

On page 22 of our Annual Report on Form 10-K for the year ended June 30, 2005
we state that "manufacturing costs and changes in inventory value for
proteins and antibodies charged to cost of sales were $6.6 million in fiscal
2005."  This amount can be reconciled to amounts included in our March 8,
2006 response as follows:

Standard cost of product sold                               $1,354,000 *
Manufacturing cost of failed lots not impacting inventory    3,690,000
Current manufacturing costs of unvalued inventory            2,312,000 *
Write-up of previously unvalued inventory                     (962,000)*
Write-down of previously unvalued inventory                    205,000 *
                                                            ----------
Protein and Antibody Cost of Goods Sold (as disclosed)      $6,599,000

     * Amount from table provided in our response dated March 8, 2006.


We hope that we have adequately addressed the oral comments we received from
the SEC on March 31, 2006.

Sincerely,


/s/ Thomas E. Oland

Thomas E. Oland
President and Chief Executive Officer

/s/ Gregory J. Melsen

Gregory J. Melsen
Chief Financial Officer

Cc   Andy LaFrence, KPMG
     Melodie Rose, Fredrikson & Byron

</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
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