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CORRESP
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      Corresp - Response to Comment Letter 051104

    November
      4, 2005

    VIA
      FACISIMILE

    Mr.
      David
      Burton

    Securities
      and Exchange Commission

    Division
      of Corporate Finance

    450
      Fifth
      Street, N.W.

    Washington,
      D.C. 20549-1004

    Tel-(202)
      824-5082

    Fax-(202)
      942-9585

    Re:   Trestle
      Holdings, Inc

    Form
      10-KSB for year ended December 31, 2004

    Filed
      March 30, 2005

    Form
      10-QSB a of June 30, 2005

    File
      No.
      0-23000

    Dear
      Burton:

    This
      letter is in response to your comment letter dated October 27, 2005. Trestle
      Holdings, Inc. assessment of InterScope Technologies as a significant
      acquisition was based on and interpretation of Regulation S-B, Item 310 (c)
      Financial Statements of Businesses Acquired or to be Acquired as
      follows:

    Compare
      the small business issuer’s proportionate share of the total assets (after
      intercompany eliminations) of the acquiree to the total consolidated assets
      of
      the small business issuer as of the end of the most recently completed fiscal
      year.

    Compare
      the small business issuer’s equity in the income from continuing operations
      before income taxes, extraordinary items and cumulative effect of a change
      in
      accounting principles of the acquiree to such consolidated income of the small
      business issuer for the most recently completed fiscal year.

    Computational
      note to paragraph (c)(2): For purposes of making the prescribed income test
      the
      following guidance should be applied: If income of the small business issuer
      and
      its subsidiaries consolidated for the most recent fiscal year is at least 10
      percent lower than the average of the income for the last five fiscal years,
      such average income should be substituted for purposes of the computation.
      Any
      loss years should be omitted for purposes of computing average
      income.

    We
      calculated the total assets as described above at less than the 20% threshold.
      For the income test, we noted the computational note (above) and did not
      consider the income test as both Companies have incurred net losses since
      inception.

    We
      now
      understand from our telephone call with you this morning that our interpretation
      of paragraph (c) (2) was incorrect and that we should have used the absolute
      values of the losses for the test. As such, we will obtain audited financial
      statements for the acquired company. Since there was no audit performed prior
      to
      the acquisition, we will have to engage a certified public accountant for this
      undertaking. We anticipate that it make take up to a month to complete the
      audit
      and disclose the required information in a Form 8-K filing.

    Should
      you have any questions or further comments please contact either me or Eric
      Stoppenhagen, our Vice President of Finance, at 949-673-1907.

    Sincerely,

    TRESTLE
      HOLDINGS, INC.

    By:_/s/
      BARRY HALL___________

    Barry
      Hall

    President
      & Chief Financial Officer