Mail Stop 3-9
Via Facsimile and U.S. Mail


	October 27, 2004


Mr. Thomas E. Oland
Chairman of the Board, President, Treasurer
   Chief Executive Officer, Chief Financial
   Officer and Director
Techne Corporation
614 McKinley Place N.E.
Minneapolis, MN 55413

Re:	Form 10-K for the fiscal year ended June 30, 2004
	Filed September 9, 2004

Dear Mr. Oland:

We have reviewed your filing and have the following comments.  We
have limited our review of the above referenced filing to only
those
issues addressed below in our comments and will make no further
review of this document.  Where our comments call for disclosure,
we
think you should revise your documents in response to these
comments
in future filings beginning with your September 30, 2004 Form 10-
Q.
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 explanation.  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.

Form 10-K, filed 9/10/04

Item 8. Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements

A. Description of Business and Summary of Significant Accounting
Policies


Short-Term Investments, pg. 32
1. Please provide, supplementally, management`s assessment of
compliance to paragraph 17 of SFAS 115 as amended by SFAS 135,
given
that the Company currently characterizes debt instruments with
maturities of three months to three years as short-term.
Inventories, pg. 32
2. We note that you produce quantities in excess of forecasted
usage.
Please tell us and clarify in the filing why you believe your
inventory balance in excess of forecasted usage does not require
an
impairment.  Also, tell us why you believe a two-years` sales
forecast is appropriate and how the sales forecast is used in
determining whether or not an impairment exists.
Investments, pg. 33
3. Please tell us your basis for recording your equity pick-up in
investees as research and development expenses instead of
equity/loss
in investments on your Statements of Operations.
4. Please clarify to us and in the filing why, prior to April
2004,
you believe it was appropriate to record 100% of the losses of CCX
in
your financial statements, as disclosed in your March 31, 2004
Form
10-Q.  Please provide to us your analysis as to why your
investment
in CCX did not qualify as a variable interest entity, as the
Company
is absorbing 100% of the operation losses of CCX.  Additionally,
please explain to us and in the filing why it was appropriate to
account for the Company`s 19.9% equity interest in CCX on the cost
basis subsequent to April 2004.
5. Please clarify to us and in the filing why you believe it is
appropriate to account for your 10% interest in Hemerus under the
equity method.

Please provide us the supplemental information requested within 10
business days of the date of this letter or tell us when you will
provide a response prior to the expiration of the 10-day period.
Please furnish a cover letter with your supplemental responses
that
keys your responses to our comments.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR
under
the form type label CORRESP.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

You may contact Kevin Woody, Staff Accountant, at (202) 942-7332
or
Mary Mast at (202) 942-1858 if you have questions regarding
comments
on the financial statements and related matters.  Please contact
me
at (202) 942-1803 with any other questions.

							Sincerely,



							James Rosenberg
							Senior Assistant Chief
Accountant
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Mr. Thomas E. Oland
Techne Corporation
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