January 26, 2005
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail

Mr. Robert L. Nelson
Chief Executive Officer
Ballistic Recovery Systems, Inc.
300 Airport Road
South St. Paul, Minnesota  55075-3541

RE:	Ballistic Recovery Systems, Inc. (the "Company")
	Form 10-KSB for the year ended September 30, 2004
	File No. 0-15318

Dear Mr. Nelson:

Based upon an examination restricted solely to considerations of
the
Financial Statements, Management`s Discussion and Analysis, and
Selected Financial Data, the staff has the following comments on
the
above-referenced document.  We think you should revise all future
filings 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
response.  In some of our comments, we may ask you to provide us
with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Please respond to confirm that such comments will be complied
with,
or, if certain of the comments are deemed inappropriate by the
Company, advise the staff of the reason thereof.

Pursuant to Rule 101(a)(3) of Regulation S-T, your response should
be
submitted in electronic form, under the label "corresp" with a
copy
to the staff.  Please respond within fifteen (15) business days.




Form 10-KSB for the Fiscal Year Ended September 30, 2004

Management`s Discussion and Analysis or Plan of Operation

Operations, page 12

1. Where changes in results are attributed to more than one
factor,
please quantify the impact of each material factor where
practicable.
For example, you state that SG&A costs increased as a result of
adjustments in staffing, marketing outsourcing, expanded trade
show
activity, increased compensation, business development expenses,
and
legal fees.

Statements of Operations, page F-4

2. We note that you classify amortization expense on the non-
compete
intangible as other expense in the statement of operations.
Please
revise to classify this cost as a component of income from
operations.  Refer to Rule 5-03(b) of Regulation S-X.

Note 2 - Summary of Significant Accounting Policies, page F-7

3. Please revise to disclose your revenue recognition policies
pursuant to SAB 104.

Note 4 - Purchase and Supply Agreement, page F-13

4. We note from disclosure in your Form 10-Q for the quarter ended
June 30, 2004, that Cirrus met their minimum purchase commitment
for
warrant number four by June 30, 2004.  We also note that the
market
price of your common stock ranged from $1.95 to $2.99 during the
quarter.  These prices were in excess of the $1.25 exercise price
of
warrant number four.  We note that you recognized $104,650 and
$20,799 of sales discounts in fiscal years 2004 and 2003,
respectively, associated with warrants issued to Cirrus.  These
sales
discounts appear to be significantly less than the fair value of
warrant number four during the quarter in which Cirrus met their
minimum purchase commitment.  Accordingly, please supplementally
tell
us the date Cirrus` met their purchase commitment on warrant
number
four, the fair value of the warrants on that date, and the key
assumptions you used in determining the fair value.

5. You state that warrants are not considered earned until the
products are sold based on EITF 96-18.  Supplementally demonstrate
whether and how your accounting complies with Issue 6 of EITF 01-
9.
Refer to Exhibit 01-9D of the EITF Consensus for guidance on
incentives in the form of equity instruments.
Other

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filing reviewed by the staff to be
certain
that they have provided all information investors require for an
informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

**********

You may contact Lyn Shenk at (202) 824-5369 or Margery Reich at
(202)
942-1839 if you have questions regarding comments on the financial
statements and related matters.  Please contact the undersigned at
(202) 942-1995 with any other questions.


								Sincerely,


								David R. Humphrey
								Branch Chief


Via facsimile:  Robert L. Nelson
		(651) 457-8651
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Mr. Robert L. Nelson
Ballistic Recovery Systems, Inc.
January 26, 2005
Page 1