[Letterhead of Registrant]



                                 October 7, 2005

VIA EDGAR
- ---------

Ms. Cecilia D. Blye, Chief
Office of Global Security Risk
Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0306

           Re:      Imaging Diagnostic Systems, Inc.
                    Form 10-K for the Fiscal Year Ended June 30, 2005
                    Form 10-Q/A for the Fiscal Quarter Ended March 31, 2005
                    File No.:  000-26028


Dear Ms. Blye:

     In connection with the review of the above-captioned Form 10-K and 10-Q/A
for Imaging Diagnostic Systems, Inc. (the "Company"), we are responding to your
request to provide supplemental information as set forth in your letter dated
September 26, 2005.

     We are and have always been fully aware of the United States Treasury
Department's exportation requirements. We do not view our contacts in the past,
our current contact or our anticipated contacts with either Libya or Iran to
materially constitute individually or in the aggregate a material investment
risk for our security holders.

     With reference to your request regarding our contact with Libya, please be
advised that we have never sold any Products to Libya at any time, from the
inception of this Company to the present. Prior to January 7, 2005 we never
entered into any Agreement with any entity to market or sell in Libya. On
January 7, 2005 we granted one of our Distributors the right to market and sell
the CTLM in Libya. However, we terminated our Distribution Agreement with that
Distributor on May 23, 2005.

     With regard to Iran, we have entered into various Distribution Agreements
granting the rights to that Distributor to market and sell in Iran. However, we
have never sold a system to a Purchaser in Iran. We applied for a license to
sell a system to a purchaser in Iran, which was granted by the United States
Treasury Department; however, we never completed that sale. In fact, all of our
Distribution Agreements contained and do contain language that the Distributor
must comply with the import/export administration and control laws and
regulations of the United States of America and the Territory, and any
amendments of such laws and regulations with respect to importation of equipment
and resale thereof. Our Agreements also state that we will fully comply with all
applicable laws of the United States and the State of Florida and that the
Distributor represents that they, with respect to the purchase, marketing, sale
and distribution of the Products will comply with all applicable laws of the
Territory.



Ms. Cecilia D. Blye, Chief
Securities and Exchange Commission
October 7, 2005
Page 2


     Our most recent Distributor, who has the rights to market and sell in Iran,
also has six (6) other countries where they represent IDSI's interests.

     Please rest assured that IDSI had always been in compliance with the rules
and regulations of the United States governmental agencies.

     Therefore, we do not feel that any possible future sales in either Iran or
Libya would represent a significant material investment risk to our
shareholders.

     Imaging Diagnostic Systems, Inc. (the "Company"), acknowledges that we are
responsible for the adequacy and accuracy of the disclosure in the filings. The
Company also acknowledges that staff comments or changes to disclosure in
response to staff comments do not foreclose the Commission from taking any
action with respect to the filings and the Company also acknowledges that it 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.


Sincerely,

IMAGING DIAGNOSTIC SYSTEMS, INC.

/s/ Timothy B. Hansen

Timothy B. Hansen
Chief Executive Officer