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CORRESP
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      IFT Corp Corresp 10-03-2005

                Intercontinental
                  Business Park

                Suite
                  322

                15402
                  Vantage Parkway East

                Houston,
                  Texas 77032

                281.219.4700

                Fax
                  281.219.4710

      October
        3, 2005

      File
        No. 1-31354

      Attn:
        Rufus Decker

      Accounting
        Branch Chief

      Division
        of Corporation Finance

      United
        States

      Securities
        and Exchange Commission

      Washington,
        D.C. 20549-7010

        Re:
          Response
          to Review Letter

      Dear
        Mr.
        Decker:

      Please
        find herein our responses ordered in the manner in which they were presented
        to
        the above reference for your review and consideration.

      We
        appreciate the manner in which you are guiding us in our compliance with
        the
        applicable disclosure requirements and, more importantly, the presentation
        to
        our shareholders in our periodic filings.

      FORM
        10-K FOR THE YEAR ENDED DECEMBER 31, 2004

      General

      Comment
        1.
        Where a
        comment below requests additional disclosures or other revisions, please
        show us
        your proposed revised disclosure in your response. With the exception of
        the
        comments below that specifically request an amendment, all revisions may
        be
        included in your future filings.

      Response
        1.
        We
        acknowledge your remarks. Please be advised that we have included revised
        language and tables where requested and/or applicable for
        you to view
        and
        which language and tables will
        be included in our future filings.
        We
        welcome any feedback you may have with respect to our proposed
        revisions.

      Comment
        2.
        Please
        note that each amendment to your Form 10-K or Forms 10-Q must include updated
        certifications in the exact form specified by Item 601 of Regulation
        S-K.

      Response
        1.
        We
        acknowledge your requirement.

      Item
        7 - Management’s Discussion and Analysis of Financial Condition and Results of
        Operations, page 9

      Liquidity
        and Capital Resources, page 11

      Comment
        3.
        Please
        disclose your commitments for capital expenditures as of December 31, 2004,
        including a description of each material commitment. In addition, please
        disclose how you anticipate funding these requirements. See Item 303(a)(2)
        of
        Regulation S-K.

      Response
        3.
        We did
        not have any specific commitments as of December 31, 2004 only general
        strategies that would require us to make capital expenditures on an as and
        when
        needed basis in carrying out such strategies, which expenditures were
        anticipated to be funded from short term loans by the Chairman of the Board.
        On
        December 31, 2004, we had fixed assets of $595,852. On March 31, 2005, we
        had
        fixed assets in the amount of $764,983, giving us capital expenditures for
        the
        quarter of $169,131. This total was comprised of (1) the assets acquired
        from
        LaPolla Industries, Inc. in the amount of $133,264; (2) purchases of office
        furniture, computers and software, equipment and leasehold improvements of
        $25,103 for Infiniti Products, Inc.; and (3) purchases of office furniture,
        computers and equipment $10,764 for IFT Corporation. All of the capital
        expenditures were either funded from the cash flow from operations and/or
        the
        Chairman of the Board.

          1

      Discontinued
        Operations, page 13

      Comment
        4.
        Please
        tell us more regarding the 2002 adjustment to eliminate the reserve related
        to
        your discontinued operations, including the nature of the contingency and
        the
        amount of the adjustment.

      Response
        4.
        Please
        review the disclosure below made in our Form 10-K for the Year Ended December
        31, 2003 for clarification in response to your comment:

      “Note
        3. Discontinued Operations.

      On
        April
        14, 1999, the Board of Directors passed a unanimous resolution to discontinue
        the activities of Designer Wear, Inc. ("DWI") and ROK International, Inc.
        ("ROK"), retroactive for the year ended December 31, 1998. DWI and ROK were
        engaged in the acquisition of license agreements for the design, contract
        manufacturing, sale, and worldwide distribution of Branded Merchandise
        products.  Rainguard Roofing Corporation was acquired, effective January 1,
        2001, primarily for the Company to field test its RSM Series™ flagship products,
        RSM-100™ and BlueMAX™, and generate revenue. The Company divested the roof
        contracting business, effective December 31, 2001, which is reflected in
        (Loss)
        from Discontinued Operations in the amount of $(1,662,183). A summary of
        the
        (loss) from discontinued operations for the years ended December
        31,

                2003

                 2002

                 2001

                Revenue

                $

                ---

                $

                ---

                $

                1,352,463

                Cost
                  of Sales

                ---

                ---

                1,949,212

                Gross
                  Profit (Loss)

                ---

                ---

                (596,749

                )

                Operating
                  Expenses

                ---

                1,021

                1,065,434

                Other
                  Income

                ---

                600,622

                188,546

                Income
                  (Loss) from Discontinued Operations

                $

                ---

                599,601

                (1,473,637

                )

      During
        2002, the Company evaluated all circumstances and that a period of five years
        had passed since any material communication relating to these commitments
        and
        contingencies, and decided that a commitments and contingency reserve was
        no
        longer required.”

      Contractual
        Obligations, page 14

      Comment
        5.
        Please
        revise your table of contractual obligations to include the estimated interest
        payments on your debt. Because the table is aimed at increasing the transparency
        of cash flow, we believe these payments should be included in the table.
        Please
        also disclose any assumptions you made to derive these amounts.

      Response
        5.
        The
        assumptions we made to derive these amounts relate to five long-term debt
        obligations that include four vehicle leases on IFT Corporation, and one
        equipment lease on Infiniti Products, Inc., books, respectively. The estimated
        interest payments remaining on this debt total $1,907.62 are included in
        our
        proposed revision below.

      Proposed
        Revision 5.

      Contractual
        Obligations

                 Payments
                  Due By Period

                Contractual

                Obligations

                 Less
                  Than

                1
                  Year

                 1-3

                Years

                 3-5

                Years

                 More
                  Than 5

                Years

                 Total

                Long-Term
                  Debt Obligations

                $

                24,582

                $

                14,243

                $

                ---

                $

                ---

                $

                38,825

                Estimated
                  Interest Payments on Long-Term Debt
                  Obligations

                1,221

                687

                ---

                ---

                1,908

                Operating
                  Lease Obligations

                155,668

                40,441

                ---

                ---

                196,109

                $

                181,471

                $

                55,371

                $

                ---

                $

                ---

                $

                236,842

            2

Item
        15, Exhibits and Financial Statement Schedules: (a)2 Financial Statement
        Schedules, page 16

      Comment
        6.
        Please
        tell us where you have provided the disclosures required by Schedule II related
        to your allowance for doubtful accounts.

      Response
        6.
        Please
        see our disclosure extracted from Page F-14 Notes to Consolidated Financial
        Statements “Allowance for Doubtful Accounts” section presented below in response
        to your comment.

      “Allowance
        for Doubtful Accounts

      The
        Company currently has an allowance for doubtful accounts reserve. The
        amount reserved for doubtful accounts is $74,339 through December 31, 2004,
        and
        $358,607 as of December 31, 2003. The balance in the allowance for doubtful
        accounts was adjusted during 2004 to more accurately estimate those accounts
        that may be uncollectible. In the past, allowance for doubtful accounts applied
        a percentage to all customer balances in the 31-60, 61-90, and over 90 day
        balances, and those percentages were deemed in excess, therefore, new
        percentages have been applied and the result was a reduction in allowance
        for
        doubtful accounts of $168,239 after an adjustment in the fourth quarter of
        2004;
        management believes these percentages more accurately depict the allowance
        for
        doubtful accounts as of December 31, 2004.”

      Item
        8 - Financial Statements

      Report
        of Independent Registered Accounting Firm, page F-2

      Comment
        7.
        We note
        the statement that the audits were conducted in accordance with the standards
        of
        the Public Company Accounting Oversight Board, “except as discussed in the
        following paragraph.” Please obtain a revised report from your independent
        accountant which states, in clear and unqualified language, that the audits
        were
        conducted in accordance with the standards of the Public Company Accounting
        Oversight Board. Please file an amendment to your Form 10-K for the year
        ended
        December 31, 2004 that includes the revised report from your independent
        accountant.

      Response
        7.
        We have
        obtained a revised report from our independent accountant to be included
        in our
        proposed amended Form 10-K and which conforms to your requirement. See Exhibit
        1.

      Comment
        8.
        Please
        also note that an explanatory paragraph included to describe the uncertainty
        about an entity’s ability to continue as a going concern should be presented
        after the opinion paragraph. See paragraph 12 of SAS 59. The revised opinion
        from your independent accountant included in your amended Form 10-K should
        conform to this requirement.

      Response
        8.
        The
        revised report from our independent accountant conforms to your requirement.
        See Exhibit
        1.

      Consolidated
        Balance Sheets, page F-4

      Comment
        9.
        You
        currently only disclose the 2003 allowance for doubtful accounts on the face
        of
        your balance sheet. If you choose to present the allowance for doubtful accounts
        on the face of your balance sheet, please present the amounts of the allowance
        for both years.

      Response
        9.
        We have
        included the 2004 allowance of $74,339 on the face of our Balance Sheet in
        our
        proposed revision below.

      Proposed
        Revision 9.

      IFT
        CORPORATION

      CONSOLIDATED
        BALANCE SHEETS

                 As
                  of December 31,

                 2004

                 2003

                Assets

                Current
                  Assets:

                Cash

                $

                24,903

                $

                42,718

                Accounts
                  Receivable (net of allowance for doubtful accounts of
                  $74,339 and $358,607 for 2004 and 2003,
                  respectively)

                630,408

                438,822

                Inventory
                  (Note 4)

                249,039

                743,104

                Prepaid
                  Expenses and Other Current Assets

                41,053

                30,499

                Total
                  Current Assets

                945,403

                1,255,143

            3

Comment
        10.
        Please
        present goodwill separately from any other intangible assets on the face
        of your
        balance sheet. Please also revise the title of the goodwill line item to
        avoid
        its confusion with other intangibles. See paragraphs 42 and 43 of SFAS
        142.

      Response
        10.
        The
        Intangibles amount of $774,000 on page F-4 is comprised entirely from the
        acquisition of Infiniti Products, Inc. Also, please refer to Note 6 in the
        “Notes to Consolidated Financial Statements” for a further breakdown of the
        Goodwill and Intangibles. We have renamed “Intangibles” to “Goodwill” on page
        F-4 on the Balance Sheet as of December 31, 2004 and 2003 in our proposed
        revision below.

      Proposed
        Revision 10.

      IFT
        CORPORATION

      CONSOLIDATED
        BALANCE SHEETS

                 As
                  of December 31,

                 2004

                 2003

                Assets

                Other
                  Assets:

                Goodwill,
                  Net (Note 6)

                774,000

                774,000

                Notes
                  Receivable

                ---

                22,693

                Deposits
                  and Other Non-Current Assets

                56,471

                46,946

                Total
                  Other Assets

                830,470

                843,639

      Comment
        11.
        Please
        amend your filing to present the Reserve for Litigation line item consistently
        for all periods presented. The reserve for litigation as of December 31,
        2003 is
        included in the Accounts Payable and Accrued Expenses line item. It is also
        unclear why you have referenced the reserve for litigation line item to note
        3.
        Further, while the tabular detail in note 7 currently includes the litigation
        reserve for both periods, only the 2003 balance is included in Total Accounts
        Payable and Accrued Expenses. Please revise as appropriate.

      Response
        11(a).
        The
        Reserve for Litigation was $929,091 as of December 31, 2003 (See
        Note 7 -
        page F-18). The proposed amendment removes the $929,091 from the Accounts
        Payable a