SecProbe.io

Mail Stop 4561         A p r i l  2 5 ,  2 0 0 8   Richard S. DeRose Chief Financial Officer Information Analysis Incorporated 11240 Waples Mill Road, Suite 201 Fairfax, VA 22030
Re: Information Analysis Incorporated
 Form 10-KSB for the Fiscal Year Ended December 31, 2007
Filed April 15, 2008
 File No. 000-22405

Dear Mr. DeRose:
We have reviewed the above referenced filing and have the following comments.
Please note that we have limited our review to only your financial statements and related
disclosures and do not intend to expand our revi ew to other portions of your document.
If indicated, we think you should revise your  document in response to these comments.
If you disagree, we will consider your explana tion as to why our comment is inapplicable
or a revision is unnecessary.  Please be as de tailed as necessary in your explanation.  In
some of our comments, we may ask you to pr ovide us with supplemental information so
we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.
 Please understand that the purpose of our re view 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.

Richard S. DeRose
Information Analysis Incorporated April 25, 2008 Page 2  Form 10-KSB for the fiscal year ended December 31, 2007

 Notes to Financial Statements, page 21

 Note 1. Summary of Significant Accounting Policies, page 21

 Revenue Recognition, page 21

 1. Explain the nature of any multiple elem ent arrangements including the accounting
treatment for each deliverable of these arra ngements.  In this regard, we note your
“fixed price contracts” ma y require the delivery of a specific product with related
customer acceptance provisions and that “a portion of [your] fixed price contracts
may involve the design and development of co mplex client systems.”  It is unclear
from your disclosure whether you apply c ontract accounting (i.e. SOP 81-1) to all
or only a portion of your “fixed price c ontracts” as the last sentence on page 21
indicates that revenues a ssociated with the customized software product is
recognized under SOP 97-2.  Your response should provide a clear understanding
of your various arrangements and the accounting guidance relied upon for each.
 Note 8. Major Customers and Major Suppliers, page 30

2. We note that you generated 28% of your to tal revenue from third party software
and maintenance contracts under agreements  with two major suppliers.  Explain
whether the revenue generated throu gh these third party software and
maintenance contracts is recorded on a gro ss or net basis and pr ovide justification
for your accounting policy in accordance with the guidance in EITF 99-19.  Further, tell us what cons ideration you gave to disc losing the revenue recognition
policy for this significant revenue stream within your  filing.

* * * * * * *

Please 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.  If you amend your
filing(s), you may wish to provide us with ma rked copies of any amendment to expedite
our review.  Please furnish a cover letter that  keys your response to our comments and
provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its

Richard S. DeRose
Information Analysis Incorporated April 25, 2008 Page 3  management are in possession of all facts re lating 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
filing;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Jason Nietha mer, Staff Accountant, at (202) 551-3855 or me at
(202) 551-3488 if you have any questions  regarding the above comments.
        S i n c e r e l y ,

      /s/ Stephen Krikorian        Stephen Krikorian
Accounting Branch Chief