SecProbe.io

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Room 4561
						August 4, 2005

Mr. David G. Mazzella
President and Chief Executive Officer
Veramark Technologies, Inc.
3750 Monroe Avenue
Pittsford, NY 14534

Re:	Veramark Technologies, Inc.
	Form 10-K for Fiscal Year December 31, 2004
	Filed March 28, 2005
	File No. 000-13898

Dear Mr. Mazzella:

      We have reviewed your response letter dated July 19, 2005
and
have the following additional comments.  We may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
After reviewing this information, we may 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 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 December 31, 2004

Consolidated Financial Statements

Note 1. Description of Business and Summary of Significant
Accounting
Policies

Revenue Recognition, page 36

1. We note that your response to prior comment number 1 did not
address any acceptance provisions related to your software license
sales.  Your proposed policy indicates that sales of licensed
software sold directly to end users are "recognized as revenue
upon
delivery and installation of the software at the customer site."
Your
current policy indicates that software license revenue is
"recognized
upon delivery and acceptance." Please explain to us the nature of
your acceptance provisions and indicate how your proposed policy
adequately addresses them.

2. Your proposed revenue recognition policy indicates that service
revenues are recognized when the service is "completed and
acknowledged by the customer," yet your current policy indicates
that
service revenues are recognized "as the services are performed."
Please explain to us the contractual terms that result in
recognizing
service revenue when the service is "completed and acknowledged by
the customer." In addition, explain to us why your proposed policy
differs from your current policy.

3. We have read your response to prior comment number 2 and note
that
the first year of "free" PCS for your VeraSMART product line is
calculated as 18% of the software price. Please confirm that this
amount represents the second year renewal price including the 5%
increase that is charged in the second year. If the 5% increase is
not included, please further explain to us how the 18% represents
your contractual renewal rate.

4. We have read your response to prior comment number 3 and note
that
you did not address whether any of your services are essential to
the
functionality of your software. However, we note that your current
and proposed revenue recognition policies appear to indicate that
you
defer recognition of license revenue until installation is
complete
and, potentially, accepted. Please explain to us how you concluded
whether your services are essential to the functionality of your
software and how deferral of your license revenue based on
installation affected that conclusion.

5. You indicate that eCAS and VeraSMART arrangements may or may
not
be multiple element arrangements as customers may arrange to
purchase
services separately.  Please tell us how you considered the
guidance
in AICPA Technical Practice Aid 5100.39 when determining that
software licenses and services should not be accounted for as part
of
multiple-element arrangements.  Additionally, tell us how you have
considered providing disclosure regarding your revenue recognition
policies for multiple-element arrangements.

6. We have read your response to prior comment 4 and note that you
did not explain how you recognize hosting fees related to the
remote
data storage hardware or set up. Please tell us how you recognize
these fees and refer to the relevant sections of SAB 104 and EITF
00-
21 that support your accounting.

	As appropriate, please amend your filing and 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.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

	You may contact Christine Davis, Staff Accountant, at (202)
551-
3408, Mark Kronforst, Senior Staff Accountant at (202) 551-3451 or
me
at (202) 551-3489 if you have questions regarding these comments.

Sincerely,

      Brad Skinner
							Accounting Branch Chief
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Mr. David G. Mazzella
Veramark Technologies, Inc.
August 4, 2005
Page 3

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