SecProbe.io

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February 11, 2005

VIA U.S. MAIL AND FAX (202-942-9594)

Larry Spirgel
Assistant Director
Mail Stop 0407
United States Securities and Exchange Commission
Washington, D.C.  20549

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

Dear Mr. Spirgel:

We are in  receipt  of your  comment  letter  dated  February  1,  2005  and our
responses are included below as a part of this correspondence.

               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 how
          you 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.

REPSONSE:

Maintenance Services

The  revenue  recognition  policy in our most  recently  filed  10-KSB  reads as
follows:

          The Company recognizes revenue from sales at the time of shipment. The
          Company's  accounts  receivable  are generated  from a large number of
          customers in the security  integration,  construction  contractor  and
          electrical  subcontractor and governmental markets. No single customer
          accounted for 10% or more of revenues  during the years ended June 30,
          2004 or 2003.

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Revenues from  maintenance  agreements  for our fiscal year ended June 30, 2004,
were $332,000.  Because revenue from maintenance agreements has not exceeded 10%
of total revenues, we have not disclosed such amounts separately.

As part of its security solution service offering, our B&B ARMR segment provides
maintenance  and  installation  services  to its  customers.  Nearly  all of the
Company's  maintenance  services  are billed and  performed  in the same  month.
Revenue on these  agreements  is recognized  monthly.  The Company has two other
agreements,  one for one year ($6,000) and one for three years ($25,000),  where
revenue is recognized at the end of each twelve-month service period.

While the Company does not expect maintenance  revenues to be a material portion
of total revenue,  we will expand the revenue  recognition  policy disclosure in
our 10-KSB filing for the year ending June 30, 2005, to include  maintenance and
service  revenues to indicate  revenues are  recognized at the time services are
completed.

Credit Risk and Filings of Liens on Jobsites

Construction  project  services  are  generally  arranged  through a contract or
purchase order with our customer.  B&B ARMR's  customer base consists  mainly of
general contractors,  municipal road & bridge contractors,  and other electrical
and mechanical  contractors who provide  services and materials to corporate and
governmental end-users.  The primary product provided to the customer's job site
consists of integrated  hydraulic  perimeter  security systems,  traffic control
barriers and lights,  and the  commissioning  of these systems in the field,  on
occasion.  B&B ARMR  recognizes  revenue at the time of  shipment or at the time
services and installation are completed.  In the event that the customer becomes
delinquent  regarding a previously agreed upon payment, B&B ARMR will review the
account and its rights under state law,  federal  law,  and  contract  rights to
determine  whether it may move forward in an attempt to file a mechanics lien on
the jobsite.  In some  instances,  B&B ARMR may be  statutorily  precluded  from
enforcing such a lien in one of the following events:

     1.   When B&B ARMR  has  previously  waived  its lien  rights  as part of a
          contract with the customer or end user;
     2.   When federal law prohibits  subcontractors  and suppliers  from filing
          liens on certain government installations;
     3.   When state law or federal  bankruptcy  law forbids the  enforcement of
          mechanics liens in certain situations;
     4.   When B&B ARMR ships to a  consolidation  point or a different  address
          from the  jobsite  and is not made aware of the final  location of the
          installed equipment.

                                       2
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During fiscal year 2004, B&B ARMR did not file any lien on any customer  jobsite
or project to recover past due indebtedness.

Note 12. Merger, page 37

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

REPSONSE:

Value of common stock issued in merger at $2.85 million

Our valuation of the ten (10) million  shares of common stock issued in exchange
for the common stock of ARMR Services  Corporation  was $2,850,000 or $0.285 per
share, as compared to the $0.38 per share on the announcement  date. The Company
engaged a third  party  valuation  expert to  prepare a  valuation  of the stock
issued and to assist with the  allocation of the purchase  price.  The following
factors were considered in the valuation:

     1.   SFAS 141 paragraph 22 states that the quoted market price of an equity
          security issued to effect a business  combination  generally should be
          used  to  estimate  the  fair  value  of  an  acquired   entity  after
          recognizing possible effects of price fluctuations, quantities traded,
          issue costs and the like.

     2.   A 25% discount was applied for lack of  marketability  because the ten
          (10) million shares,  which were issued to two  individuals,  were not
          registered  with the Securities and Exchange  Commission  ("SEC") and,
          therefore,  were  subject  to SEC  Rule  144.  The  25%  discount  was
          primarily based on the following:

          a.   We have issued shares of  unregistered  stock,  at a 25% discount
               from the market prices of our stock,  to the  following  parties:
               our preferred stockholders in lieu of dividends,  to debt holders
               in  lieu  of  interest,  and to  certain  directors  in  lieu  of
               directors' fees.

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          b.   Potential  willing  buyers of the ten (10) million  shares likely
               would require a minimum discount of 25% for the following reasons
               (in view of the Rule 144 restrictions):

               i.   The size of the block (16% of total shares outstanding as of
                    September 30, 2003 and 60% of the public float).
               ii.  Our stock is traded on the Over the Counter Bulletin Board.
               iii. Our balance sheet reflects negative stockholders' equity.
               iv.  We incurred operating losses from fiscal 2000 through 2003.
               v.   Our auditors  have issued  "going  concern"  opinions in the
                    fiscal years ended June 30, 2000 through 2003.

     4.   As a result,  we valued the stock  issued at  $2,850,000  as  computed
          below:

               Shares issued at market price                       $3,800,000
               Less: 25% discount for lack of marketability           950,000
                                                                   ----------
               Valuation                                           $2,850,000

 The company acknowledges the following:

     o    the  company is  responsible  for the  adequacy  and  accuracy  of the
          disclosures in its filings;
     o    staff  comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any action with respect to
          its filings; and
     o    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.

 If you have any further questions, please do not hesitate to contact me.

 Regards,

 /S/ C. A. Rundell, Jr.
 ----------------------
 C. A. Rundell, Jr.
 Chief Executive Officer and
 Principal Executive and Financial Officer

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