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October 17, 2005

Via EDGAR

    U.S. Securities and Exchange Commission

    Veramark Technologies, Inc.

    Division of Corporation Finance

    3750 Monroe Ave

    100 F Street, N.E.

    Pittsford, NY 14534

    Washington, D.C. 20549

    Attention: Christine Davis

    RE:

    Veramark Technologies, Inc

    Form 10-K for the period ending December 31, 2004, filed March 28, 2005

    File No. 001-13898

    Comment Letter #3, Dated October 3, 2005

Dear Ms. Davis:

The following are the responses of Veramark Technologies, Inc. to the comment letter issued by the
SEC on October 3, 2005. If you require any additional information or clarification, please do not
hesitate to contact me at 585-383-6807. Thank you.

As per our telephone conversation of September 26, 2005 and your letter of October 3, 2005, you ask
for clarification as to why we continue to believe 18% is the correct value to assign to first year
software maintenance when sold as part of a multi-element transaction which involves both VeraSMART
software product and one year of embedded maintenance. It is our belief that only applying bullet
number 1 of paragraph 10 of SOP 97-2 does not capture the true underlying economic transaction.

Our policy of incrementing the price for maintenance by 5% annually, based upon a starting point of
18% of list price, computes to a first year renewal price equivalent to 18.9% of the list price.
In the second year of renewal, that will compute to 19.8% of list price, and so on. By only
adhering to the first bullet of paragraph 10, without consideration of the final sentence of
paragraph 10 (which states, “When a vendor’s pricing is based on multiple factors...the amount
allocated...must consider all the factors of the vendor’s pricing structure.”), Veramark would be
recognizing the same amount for maintenance in both the first and second year of the contract, even
though it is our intention to create an economic transaction that increments the amount by 5%
during the second and subsequent maintenance years. Thus, we believe that the customer’s execution
of and willingness to pay for a maintenance contract based upon this pricing structure, is VSOE
that a first year value based upon a percentage of the first year renewal price (that is the
renewal price less the 5% increment) is a more accurate reflection of the true economics of the
transaction.

You requested that we present an analysis showing the effect of adjusting our numbers from the
methodology we are currently using, to the methodology exactly detailed in SOP 97-2, paragraph 10,
bullet 1. Attached please see exhibit 99.1, showing that the impact of adjusting these numbers is
inconsequential, with the net income of no single quarter being adjusted by greater than $5,000, or
 .16% (.0016) of revenue.

Page 1 of 2

Though we disagree with your conclusion that VSOE does not exist to support our current policy, we
will however, effective with the third quarter of 2005, begin to defer the first year maintenance
at a value equivalent to the first year renewal rate.

Regarding the impact on the evaluations of our disclosure controls and procedures, we believe this
review has been a beneficial experience for us. As we continue to move forward with compliance of
section 404 of the Sarbanes Oxley Act, we will incorporate the findings of this review into our
internal control structure within the deadline as set forth by the SEC for small companies.

Sincerely,

/s/ Ronald C. Lundy

Ronald C. Lundy

Treasurer, Chief Accounting Officer

Page 2 of 2

Exhibit 99.1

Veramark Technologies, Inc.

Impact on Net Income of Deferring VeraSMART Embedded Revenue

As per October 3 Correspondence with SEC

    Net

    Less Additional

    Less Original

    Plus Adjusted

    Adjusted Net

    Change In

    Reported Sales

    Income/(Loss)

    Maint Deferred

    Maint Recognized

    Maint Recognized

    Income/(Loss)

    Reported Income

    Q3 - 03

    2,917,179

    109,528

    (1,384
    )

    —

    —

    108,144

    (1,384
    )

    Q4 - 03

    2,844,153

    465,935

    (446
    )

    (5,429
    )

    5,701

    465,761

    (174
    )

    Q1 - 04

    2,763,698

    25,538

    (139
    )

    (8,868
    )

    9,312

    25,843

    305

    Q2 - 04

    2,567,599

    (521,386
    )

    (1,671
    )

    (10,778
    )

    11,317

    (522,518
    )

    (1,132
    )

    Q3 - 04

    2,781,986

    (33,759
    )

    (1,336
    )

    (16,082
    )

    16,886

    (34,291
    )

    (532
    )

    Q4 - 04

    3,012,683

    416,047

    (6,146
    )

    (25,743
    )

    27,031

    411,189

    (4,858
    )

    Q1 - 05

    2,626,372

    (85,286
    )

    (2,827
    )

    (49,236
    )

    51,698

    (85,651
    )

    (365
    )

    Q2 - 05

    2,661,356

    249,723

    (2,206
    )

    (60,213
    )

    63,225

    250,529

    806

    Q3 - 05

    (1,689
    )

    (70,818
    )

    74,360

    1,853

    1,853

    Q4 - 05

    (58,029
    )

    60,930

    2,901

    2,901

    Q1 - 06

    (31,097
    )

    32,652

    1,555

    1,555

    Q2 - 06

    (18,209
    )

    19,119

    910

    910

    Q3 - 06

    (2,302
    )

    2,417

    115

    115

    (17,844
    )

    (356,804
    )

    374,648

    —