SecProbe.io

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Mail Stop 0407

      							February 1, 2005

Via U.S. Mail and Fax (972-869-3843)
Mr. C.A. Rundell, Jr.
Chief Executive Officer and Principal Executive and Financial
Officer
Integrated Security Systems, Inc.
8200 Springwood Drive
Suite 230
Irving , TX 75063

	RE:	Integrated Security Systems, Inc.
      Form 10-KSB for the fiscal year ended June 30, 2004
		File No. 1-11900

Dear Mr. Rundell:

      We have reviewed the above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.  Please address the following
comments in future filings.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a future
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-KSB for the Fiscal Year Ended June 30, 2004

Item 7. Financial Statements

Note 2. Revenue Recognition, page 25

1. We note that in your B&B ARMR segment you provide maintenance
services to customers.  Please tell us how the services are
structured and you accounting are accounting for the services.  In
addition please tell us the dollar amount of sales generated
through
these services.  We further note that on page 27 under
Concentration
of Credit Risk you file statutory liens on construction projects
where collection problems are anticipated.  Please tell us how
these
construction project services are arranged and how you account for
them.

Note 12. Merger, page 37

2. Please tell us how you valued the common stock issued at $2.85
million.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested supplemental information.  Please file your response
letter
on EDGAR.

	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 they have provided all information investors require
for
an informed 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 filings; 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 filings or
in
response to our comments on your filings.

      You may contact Michael Henderson, Staff Accountant, at
(202)
824-5551 or Dean Suehiro, Senior Staff Accountant, at (202) 942-
1894
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 942-1990 with any
other questions.

							Sincerely,

							Larry Spirgel
							Assistant Director

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Mr. C.A. Rundell, Jr.
Integrated Security Systems, Inc.
February 1, 2005
Page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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