Room 4561
February 16, 2006

Mr. Paul W. Bridge, Jr.
Chief Financial Officer
LanVision Systems, Inc.
10200 Alliance Road Suite 200
Cincinnati, OH 45242

      Re:	LanVision Sytems, Inc.
      Form 10-K for the Fiscal Year Ended January 31, 2005
		Filed April 8, 2005
      File No. 0-28132

Dear Mr. Bridge:

      We have reviewed your response letter dated February 9, 2006
and have the following comment.  Please note that we have limited
our
review to the matters addressed in the comments below.  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 comment 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 for the Fiscal Year Ended January 31, 2005

Financial Statements

Notes to Financial Statements

Note 1. Organization and Summary of Significant Accounting
Policies

Revenue Recognition, page 37
1. We have read your response to prior comment number 5 and note
that
you recognize 100% of the revenue upon receiving the royalty
report
from IDX.  Please tell us more about the payment terms and the
related milestones.  Specifically, address how the milestone
payment
contingency and extended payment term is considered in determining
that the entire amount of revenue is fixed or determinable upon
receiving the royalty report.

      As appropriate, please respond to these comments within 10
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 furnish a cover
letter that keys your responses to our comments and provides any
requested information.  Detailed cover letters greatly facilitate
our
review.

      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 Mark Kronforst, Senior Staff Accountant, at
(202) 551-3451 or me at (202) 551-3489 if you have any questions
regarding these comments.


							Very truly yours,


							Brad Skinner
						Accounting Branch Chief
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Paul W. Bridge, Jr.
LanVison Systems, Inc.
February 16, 2006
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