SecProbe.io

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Room 4561
						October 3, 2005

Mr. Ronald C. Lundy
Treasurer, Chief Accounting 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. Lundy:

      We have reviewed your response letter dated August 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. It remains unclear why you believe that VSOE of maintenance on
your VeraSMART product is 18% of the license fee. Please identify
the
specific VeraSMART transactions in which maintenance has been sold
separate from the software license at 18% of the original license
fee. Currently, it appears to us that customers are only able to
purchase maintenance separate from the license in the form of the
first year renewal at a price amounting to 18.9% (18% stated rate
plus 5% increase) of the original license fee. If you are unable
to
support the 18% rate as VSOE, provide us with an analysis that
shows
the effect of correcting your policy for all periods presented and
the subsequent interim periods. In addition, explain to us how you
and your auditors concluded that your policy is in compliance with
generally accepted accounting principles and describe the impact
of
this correction, if it is necessary, on the evaluations of your
disclosure controls and procedures.

	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. Ronald C. Lundy
Veramark Technologies, Inc.
October 3, 2005
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