SecProbe.io

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December 8, 2005

Office of the Chief Counsel
Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549

Re:      Alanco Technologies, Inc. ("Alanco" or "Company")
         Preliminary Proxy Statement on Schedule 14A filed November 28, 2005
         File No. 0-09347

To Whom It May Concern:

Alanco received a comment letter, dated December 6, 2005, pertaining to a review
by the SEC of the above referenced Preliminary Proxy Statement filing. The
comment letter focused primarily on the proposal in the Proxy Statement to
authorize, only if necessary, a reverse split of the Company's Class A Common
Stock. Comments were also made with respect to disclosure controls and
procedures required pursuant to Rule 15d-15 under the Exchange Act and Item 307
of Regulation S-B.

We have filed an amended Preliminary Proxy Statement modifying our disclosures
as requested. We are also providing you with four (4) marked copies of that
filing as an attachment to this cover letter.

Presented below are the SEC comments specified in the December 6, 2005 letter
and, in italics, the Company's response or proposal to resolve deficiencies
noted:

Preliminary Proxy Statement on Schedule 14A

Proposal No. 4, page 13

    1.   Please advise us how you have complied with Arizona law with respect to
         your proposed treatment of any fractional shares upon a reverse stock
         split.

         Comment - The Company has modified the Preliminary Proxy Statement to
         indicate the alternatives under Arizona law and the intent of the
         Company's Board of Directors to make the appropriate determination
         relative to fractional shares, if and when the reverse stock split is
         effected. See page No.14 of the Amended Preliminary Proxy filing.

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    2.   We note your disclosure that the purpose of the reverse stock split is
         to increase the trading price of your common stock in order to meet
         listing standards. Please disclose the trading volume and the price of
         your common stock as of a recent date.

         Comment - Current stock price and trading volumes are presented on
         page 14.

    3.   We note that a reverse stock split will result in an increase in your
         authorized shares of common stock. Please provide a table illustrating
         the effect on the number of authorized shares of common stock available
         for issuance as a result of your reverse split over the range of ratios
         you are seeking approval for.

         Comment - The reverse stock split will not increase the Company's
         authorized shares of Class A Common Stock. However, it will increase
         the authorized shares available for issuance as a result of the reverse
         split. We have provided a table illustrating that effect on pages 15 of
         the amended Preliminary Proxy filing..

    4.   Please disclose whether you presently have any plans, proposals or
         arrangements to issue any of the newly available authorized shares of
         common stock for any purpose, including future acquisitions and/or
         financings. If so, please disclose by including materially complete
         descriptions of the future acquisitions and/or financing transactions.
         If not, please state that you have no such plans, proposals, or
         arrangements, written or otherwise, at this time to issue any of the
         additional authorized shares of common stock.

         Comment - We do not have any such plans and that has been disclosed on
         Page 15 of the amended Preliminary Proxy filing.

    5.   In light of the increase in available capital as a result of your
         reverse stock split, please refer to Release No. 34-15230 and discuss
         the possible anti-takeover effects of the increase in available
         capital. Please also discuss other anti-takeover mechanisms that may be
         present in your governing documents or otherwise and whether there are
         any plans or proposals to adopt other provisions or enter into other
         arrangements that may have material anti-takeover consequences. Inform
         holders that management might use the additional shares to resist or
         frustrate a third party transaction providing an above-market premium
         that is favored by a majority of the independent stockholders.

         Comment - The Company has no anti-takeover mechanisms present in our
         governing documents that would be enhanced by an increase in the number
         of authorized shares available for issuance. See Page 16 of the current
         Preliminary Proxy filing for a discussion of anti-takeover implications
         of a reverse stock split.

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Form 10-KSB for the year ended June 30, 2005

    6.   It does not appear that your disclosure with respect to your disclosure
         controls and procedures conforms to the requirement of Rule 15d-15
         under the Exchange Act and Item 307 of Regulation S-B. We note your
         discussion of "various evaluations" of your disclosure controls and
         procedures in which your officers "believed (such) controls and
         procedures (to be) effective" but only to the extent of "ensur(ing)
         that (you are) able to collect, process and disclose the information
         (you) are required to disclose." Pursuant to Rule 15d-15(b) and Item
         307, your officers must perform an evaluation of your disclosure
         controls and procedures as of the end of each fiscal quarter. In
         addition, your officers must determine whether such disclosure controls
         and procedures are effective to ensure that information required to be
         disclosed by you in the reports that you file or submit under the
         Exchange Act is recorded, processed, summarized and reported, within
         the time periods specified in the Commission's rules and forms and that
         such information is accumulated and communicated to your management,
         including your principal executive and principal financial officers, or
         persons performing similar functions, as appropriate to allow timely
         decisions regarding required disclosure. Accordingly, please advise us
         if and/or whether your officers determined your disclosure controls and
         procedures, as defined pursuant to Rule 15d-15(e), are effective as of
         June 30, 2005 and September 30, 2005. Please also confirm to us that
         you will consider this comment in preparing future periodic reports.

         Comment - Alanco Management has reviewed your comments relative to Rule
         15d-15 under the Exchange Act and Item 307 of Regulation S-B and has
         determined our disclosure controls and procedures, as defined, are
         effective as of June 30, 2005 and September 30, 2005. In addition, we
         will consider your comment in preparing future periodic reports.

    7.   We note that your definition for internal controls differ from the
         definition for internal control over financial reporting that is set
         forth in Rule 15d-15(f) under the Exchange Act. Please advise us
         whether your internal controls conform to the definition set forth in
         Rule 15-15(f). We also note your disclosure that "(s)ince the date of
         the most recent evaluation...there have been no significant changes in
         such controls or in other factors that could have significantly
         affected those controls." Please note that Item 308 of Regulation S-B
         requires the disclosure of any change in your internal controls that
         occurred during your "last fiscal quarter" that has "materially
         affected, or is reasonably likely to materially affect," your internal
         controls. In light of the foregoing, please advise us with respect to
         changes in your internal controls over financial reporting for the
         quarters ended June 30, 2005 and September 30, 2005. Please also
         confirm to us that you will consider this comment in preparing future
         periodic reports.

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         Comment - We have reviewed the definition for internal controls as set
         forth in Rule 15d-15(f) under the Exchange Act and have determined the
         Company's definition of internal controls conform to that definition.
         We also understand that Item 308 of Regulation B requires the
         disclosure of any change in the Company's internal controls that
         occurred during our "last fiscal quarter" that has "materially
         affected, or is reasonable likely to materially affect" the Company's
         internal controls over financial reporting for the period reported. We
         have considered this requirement in reviewing the internal controls for
         the quarters ended June 30th and September 30th 2005 and have
         determined that no changes in the Company's internal controls has
         occurred during the quarter ended June 30, 2005 and September 30, 2005
         that has materially affected, or is reasonably likely to materially
         affect the Company's internal controls over financial reporting for the
         identified periods. We will address this requirement for all future
         reporting periods.

If you have any questions, please contact John Carlson directly at
480) 505-4869 or Adele Mackintosh directly at (480) 505-4857.

Sincerely,

/s/John A. Carlson                               /s/Adele Mackintosh

John A. Carlson                                  Adele Mackintosh
Executive Vice President and CFO                 Corporate Secretary

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