SecProbe.io

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Mail Stop 6010

      October 27, 2005

Via Facsimile and U.S. Mail

Mr. Barry Hall
President and Chief Financial Officer
Trestle Holdings, Inc.
199 Technology Dirve, #105
Irvine, CA   92618

	Re:	Trestle Holdings, Inc.
		Form 10-KSB for the year ended December 31, 2004
Filed March 30, 2005
Form 10-QSB as of June 30, 2005
		File No. 0-23000

Dear Mr. Hall:

      We have reviewed your filing and have the following comment.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
future
filings in response to this comment.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-QSB as of June 30, 2005

Note 1. Significant Accounting Policies

Current Operations and Background

1. We note that you acquired InterScope Technologies on March 11,
2005.  We further note that InterScope Technologies reported a net
loss of $1.8 million for the year ended December 31, 2004.  It
appears that this acquisition is a significant acquisition as
defined
in Item 310(c) of Regulation S-B.  Please provide us with your
calculations of the significance of the acquisition under Item
310(c)(2) of Regulation S-B.  Please file an amendment to your
Form
8-K dated March 16, 2005 to include the audited financial
statements
and unaudited pro forma financial statements for the appropriate
number of periods as specified in Item 310(c)(3) of Regulation S-
B.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response 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
your
amendment and responses 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 information required under the Securities and
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
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 advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact David Burton, Staff Accountant, at (202)
551-
3626 or me at (202) 551-3643 if you have questions regarding this
comment.  In this regard, do not hesitate to contact Michele
Gohlke,
Branch Chief, at (202) 551-3327.

							Sincerely,

      Kevin L. Vaughn
					  		Reviewing Accountant

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Mr. Barry Hall
Trestle Holdings, Inc.
October 27, 2005
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