Mail Stop 6010

      June 3, 2005




Mr. Charles J. Novak
Principal Financial and Accounting Officer
1850 Research Park Drive
Davis CA 95161-4884

	RE:	Integrated Surgical Systems, Inc.
		Form 10-K for the fiscal year ended December 31, 2004
		Filed 4/15/05
		File No. 1-12471

Dear Mr. Novak:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
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
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 for the period ending December 31, 2004

Management`s Discussion and Analysis or Plan of Operation - page 9

Liquidity - page 11

1. In view of the uncertainties concerning the continued existence
as
a going concern, the filing should contain a reasonably detailed
description of management`s specific viable plans intended to
mitigate the effect of such conditions and management`s assessment
of
the likelihood that such plans can be effectively implemented.
Those
elements of the plan that are particularly significant or critical
to
overcoming the present financial difficulties should be clearly
identified and discussed.  Additionally, there should be a
reasonably
detailed discussion of your ability (or inability) to generate
sufficient cash to support its operations during the twelve-month
period following the date of the most recent balance sheet
presented.
You should describe the plan in both the management`s discussion
and
analysis of liquidity and the notes to the financial statements.
Refer to Regulation S-B Item 303.

Item 8A. Controls and Procedures - page 20

2. We note your statement that the chief executive officer and
chief
financial officer have concluded that the company`s disclosure
controls and procedures are effective "except as described."
Given
the exceptions noted, it remains unclear whether your chief
executive
officer and chief financial officer have concluded that your
disclosure controls and procedures are effective.  Please revise
your
disclosure to state, in clear and unqualified language, the
conclusions reached by your chief executive officer and your chief
financial officer on the effectiveness of your disclosure controls
and procedures.  For example, if true, you can state that your
disclosure controls and procedures are effective including
consideration of the identified matters, so long as you provide
appropriate disclosure explaining how the disclosure controls and
procedures were determined to be effective in light of the
identified
matters.  Or, if true, you can state that given the identified
matters, your disclosure controls and procedures are not
effective.
You should not, however, state the conclusion in your current
disclosure, which appears to state that your disclosure controls
and
procedures are effective except to the extent they are not
effective.

Note 1. Description of Business and Basis of Presentation - page
38

3. Please explain the accounting for the liquidation proceedings
for
Innovative Machines International, S.A.   Is the liquidation
complete?  If not, when do you anticipate completion? Will this
significantly impact your financial statements?  Please advise.


*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff 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 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 filings;

* 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 Dennis Hult, Staff Accountant, at (202) 551-
3618 or myself if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3554 with any other questions.


								Sincerely,



								Angela J. Crane
								Accounting Branch Chief

??

??

??

??

Charles J. Novak
Integrated Surgical Systems, Inc.
June 3, 2005
Page 3