Room 4561

								March 27, 2006

Bradley T. Miller
Chief Financial Officer
Viisage Technology, Inc.
296 Concord Road, Third Floor
Billerica, Massachusetts 01821

Re:	Viisage Technology, Inc.
Form 8-K filed on March 24, 2006
      File No. 0-21559

Dear Mr. Miller:

      We have reviewed the above referenced filing and have the
following comment.  Where indicated, we think you should revise
your
filing in response to this comment.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
revision unnecessary.  Please be as detailed as necessary in your
explanation.

	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 comment or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 8-K filed on March 24, 2006
1. Revise to state whether the former accountant resigned,
declined
to stand for re-election or was dismissed, as required by Item
304(a)(1)(i) of Regulation S-K.  It is not sufficient to state
that
the former accountant "will no longer serve", as that wording is
unclear to a reader.

      As appropriate, please amend your filing and respond to this
comment within five business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.
Please
understand that we may have additional comments after reviewing
any
amendments and your responses to our comments.



	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 comment, 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 comment on your filings.

	You may contact Tamara Tangen, Staff Accountant, at (202)
551-
3443 or me at (202) 551-3488 with any questions.

      Sincerely,



      Stephen G. Krikorian
      Branch Chief - Accounting

Bradley T. Miller
Viisage Technology, Inc.
March 27, 2006
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