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<SEC-DOCUMENT>0000842023-06-000029.txt : 20061020
<SEC-HEADER>0000842023-06-000029.hdr.sgml : 20061020
<ACCEPTANCE-DATETIME>20060606100845
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000842023-06-000029
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20060606

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 28, 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.  On April 11,
2006, we also replied to oral comments received from the SEC on March 31,
2006.  The following supplements our previous responses and replies to an
additional oral comment communicated by SEC Staff Accountant, Vanessa
Robertson, to Techne Corporation Chief Financial Officer, Greg Melsen, via a
phone conversation on Thursday, April 27, 2006.

As outlined in our communications with the SEC, our periodic disclosure of
Critical Accounting Policies and in Management's Discussion and Analysis of
Financial Condition and Results of Operations, 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.  Due to changes in
the Company's forecasts, reserves for previously written-off inventories may
be reversed in subsequent years, but the amounts are not quantitatively or
qualitatively material to the Company's consolidated results of operations,
consolidated financial position, assets or stockholders' equity.

In addition to the expanded disclosure regarding the valuation of inventories
that was communicated to the SEC on March 8, 2006, we will add further
disclosure regarding changes to our inventory valuation policies that in
substance will state:

"In future periods, the Company will change its policy of writing-up
previously unvalued inventories.  This change in valuation methods is not
expected to materially impact the Company's consolidated financial
statements."

We will add the expanded disclosures as communicated in our March 8, 2006
letter, as amended above, to our quarterly report on Form 10-Q for the
quarter ended March 31, 2006.  We hope that we have adequately addressed the
oral comment we received from the SEC on April 27, 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







2

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