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<SEC-DOCUMENT>0000842023-08-000040.txt : 20090122
<SEC-HEADER>0000842023-08-000040.hdr.sgml : 20090122
<ACCEPTANCE-DATETIME>20081114111105
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000842023-08-000040
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20081114

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>
November 13, 2008


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, 2008
	File No. 000-17272



Dear Mr. Rosenberg:

This letter is in response to the comment letter received by us dated
November 3, 2008, concerning comments to our Form 10-K for the year ended
June 30, 2008.

In connection with this response, Techne acknowledges that:

  - the company is responsible for the adequacy and accuracy of the
    disclosures 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 federal
    securities laws of the United States.



COMMENT AND RESPONSE:

Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations, page 16

1.  Comment:  Although you discuss increased sales volume and the impact of
    foreign exchange rate changes on net sales, you do not appear to discuss
    the impact of price changes or new product offerings on your net sales.
    Please revise your disclosure to separately discuss the impact of price
    changes, volume changes, foreign exchange rate changes and new product
    offerings on your net sales.  See Item 303(a)(3)(iii) of Regulation S-K.

    Response:  The Company currently has over 12,000 biotechnology products
    (94% of consolidated sales).  The average annual sales per biotechnology
    product is approximately $20,000 with no one single product having annual
    sales over $3.0 million (less than 1.2% of consolidated sales).
    Therefore, price changes to an individual or a small group of products
    would not have a material effect on sales.

    The Company very seldom does across-the-board price increases.  The most
    recent was January 1, 2006 (mid-fiscal 2006) and the effect on sales
    increases was disclosed on in the 10-K for fiscal 2006 and 2007 and
    included on page 17 of the 10-K for June 30, 2008: "Approximately $1.2
    million of the increase in biotechnology net sales for fiscal 2007 was
    the result of price increases."  The Company will continue to disclose
    the effect of price changes on sales if the amount is material.

    The Company releases 1,300 to 1,500 new products each year.  We will
    revise our future disclosures to include the effect of new products on
    sales revenue beginning in the 10-Q for the quarter ended December 31,
    2008 as follows:

    "Included in consolidated net sales for the quarter and six months ended
    December 31, 2008, was $x,xxx and $x,xxx of sales of new biotechnology
    products which had their first sale in fiscal 2009."


Market Risk, page 23

2.  Comment:  On page 10 you indicate that approximately 31% of your revenues
    are denominated in foreign currency.  It appears that a significant
    percentage of your revenues in the future are expected to be denominated
    in foreign currencies.  Please revise your disclosure to indicate the
    amount of trade receivables and accounts payable denominated in foreign
    currencies and provide either the tabular presentation, a sensitivity
    analysis or the value at risk disclosures for your foreign currency
    exchange rate exposures as required by Item 305(a) of Regulation S-K.
    Otherwise, please explain to us why these disclosures are not warranted.

    Response:   We will revise our disclosure beginning in the 10-Q for the
    quarter ended December 31, 2008 to include the following:

    "The Company's exposure to foreign exchange rate fluctuations also arises
    from trade receivables and accounts payables denominated in foreign
    currencies.  At December 31, 2008, the Company had the following trade
    receivable and accounts payable denominated in foreign currencies (in
    thousands):
                                 In                     In
                          Foreign Currency          U.S. Dollars
                          ----------------          ------------
    Accounts Receivable:
      Euro                       x,xxx                   $x,xxx
      British pound	         x,xxx                    x,xxx
      Chinese yuan                 xxx                       xx

    Accounts Payable:
      Euro                         xxx                  $   xxx
      British pound              x,xxx                    x,xxx
      Chinese yuan               x,xxx                      xxx

    Intercompany payable:
      Euro                         xxx                  $   xxx
      British pound              x,xxx                    x,xxx
      Chinese yuan               x,xxx                      xxx

    All of the above balances are revolving in nature and are not deemed to
    be long-term balances."



Item 8. Financial Statements and Supplementary Data
Notes to Consolidated Financial Statements  L. Segment Information, page 39.

3.  Comment:  Please revise the geographic information to exclude intangible
    assets from the table presented here.  Refer to question 22 in the FASB
    Implementation Guide to FAS131.

    Response:  We will exclude intangible assets from the geographic
    information beginning with the 10-K for fiscal 2009.


4.  Comment:  Please revise your disclosure to provide your revenue for each
    group of similar products and services or tell us where you have made
    this disclosure in your financial statements.  Please see paragraph 37 of
    SFAS 131.  Although you offer over 12,000 biotechnology products, it
    appears that the groupings of cytokines and enzymes, antibodies, assay
    kits, clinical diagnostic kits, flow cytometry products and cell
    signaling products you disclose in Business on page 4 would be
    appropriate.

    Response:  SFAS 131 paragraph 37 states: "An enterprise shall report the
    revenues from external customers for each product and service or each
    group of similar products and services unless it is impracticable to do
    so."

    The Company considers all of its biotechnology products as one group of
    similar products. These products are all biological reagents, have
    similar gross margins and are sold to the same customer base who use them
    in research and/or diagnostic activities.  The products outlined on page
    4 are all interlinked. Cytokines/enzymes are used to produce antibodies.
    Cytokines and antibodies are sold separately, but also are raw materials
    used in the assay and clinical diagnostic kits.  Flow cytometry products
    are labeled antibodies.  Based on the above, the Company believes its
    current disclosure is appropriate.

          ************

We hope that we have adequately addressed your Comment Letter dated November
3, 2008.

Sincerely,

/s/ Thomas E. Oland

Thomas E. Oland
President and Chief Executive Officer

/s/ Gregory J. Melsen

Gregory J. Melsen
Chief Financial Officer

Cc:  Travis Rabe, KPMG
     Melodie Rose, Fredrikson & Byron
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