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SEC Response Letter

 1913 Deerbrook Drive

 Tyler, Texas 75703

 (903) 595-8808

 March 15, 2005

 Larry M. Spirgel

 Assistant Director

 U.S. Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D.C. 20549

 Dear Mr. Spirgel:

 We have reviewed your letter dated February 14, 2005 and respectfully submit the following responses to your comments.

 Teletouch Communications, Inc. (the “Company”) recognizes that it is responsible
for the adequacy and accuracy of the disclosure in the filings and that any United States Securities and Exchange Commission (the “Commission”) staff comments or changes to disclosure in response to staff comments do not foreclose the
Commission from taking any action against the Company with respect to the filings. Further, the Company acknowledges that it 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.

 Form 10-K for the year ended May
31, 2004

 Managements Discussion and Analysis, page 13

 SEC Comment:

 1. In future filings, expand the last paragraph of 16, and elsewhere as needed, to discuss
material changes from year to year in each line item to the extent necessary for an understanding of your businesses as required by Instruction 4 of Item 303(a) of Regulation S-K. Explain and individually quantify the material factors underlying
each material line item change as required by Financial Reporting Codification Sections 501.04.

 Company Response:

 We have
reviewed section 501.04 of the Financial Reporting Releases and understand the necessity of providing explanation by line item of any material changes. We will comply on future filings by discussing material changes by financial statement line item.

 Reports of Registered Public Accounting Firms, page F-2

 SEC Comment:

 2. We note that, in the third paragraph of page F-2, the report of BDO Seidman provides an opinion on financial statements prepared in
conformity with the standards of the Public Company Accounting Oversight Board (PCAOB). The PCAOB, however, does not set US accounting standards. Please amend to include an auditors opinion that clearly identifies the accounting principles and
practices reflected in the financial statements as required by Rule 2-02(c)(1) of Regulation S-X.

 Company Response:

 We have
discussed this item with BDO Seidman and they will re-issue their opinion stating that the financial statements were prepared in conformity with U.S. generally accepted accounting principles. We request that we be allowed to correct this
administrative error by filing an amendment to our Form 10-K for our year ended May 31, 2004 which would include only the revised opinion from BDO Seidman.

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March 15, 2005

 Consolidated Statements of Operations, page F-6

 SEC Comment:

 3. Refer to the fourth paragraph of page 3 and footnotes (6) and (7) of page ii of Form 10-K/A#1, which suggests that TLL Partners and the Teletouch are under the common
control of Chairman Robert McMurrey. Does Mr. McMurrey control both of these companies? Please explain to us supplementally. See paragraph 2 of SFAS 57 and expand future filings to include more robust disclosure of your related party transactions.

 Company Response:

 Teletouch and TLL Partners are not under the common control of Robert M. McMurrey.

 Robert M. McMurrey is the founder and the Chairman of the Board of Teletouch.
Mr. McMurrey owns directly 40,442 shares of Teletouch common stock and has vested options to acquire an additional 16,666 shares at $0.24 per share. In addition, Mr. McMurrey has indirect investments in Teletouch through TLL Partners and Rainbow
Resources, Inc. (“RRI”). RRI, which owns 1,200,000 Teletouch common shares, is a Texas corporation of which Mr. McMurrey is the sole director and shareholder. The principal business of RRI is the ownership and operation of oil and gas
properties and the ownership of Teletouch securities. The combined direct ownership of Teletouch held by Mr. McMurrey as of May 31, 2004 was 1,240,442 shares that can be voted or 27.3% of the outstanding 4,546,980 common stock of Teletouch. Since
Mr. McMurrey does not hold more than 50% of the voting ownership interest, Teletouch is not under his common control.

 TLL Partners is a Delaware limited liability company of which Robert M. McMurrey is the sole officer. TLL Partners is a wholly owned subsidiary of Progressive Concepts
Communications, Inc., a Delaware corporation (“PCCI”). The principal business of TLL Partners is to act as a holding company for PCCI’s investment in Teletouch equity securities. TLL Partners owns 1,000,000 Series C Preferred
Teletouch shares, which are convertible after May 20, 2005 into 44,000,000 common shares. The Series C Preferred shares are non-voting, except in matters that relate to changes in control or equity dilution of Teletouch. Mr. McMurrey currently owns
94.92% of the Common Stock of PCCI, although his percentage ownership may be changed through the exercise of outstanding convertible securities. Further, certain holders of PCCI subordinated debt may be said to exercise control of PCCI through
various negative financial covenants. Assuming no dilution of Mr. McMurrey’s ownership of PCCI, if he were to control the conversion of his prorated portion of the TLL Partners shares into common shares after May 20, 2005, his total
direct ownership of Teletouch would be 43,005,242 shares that could be voted or 92.9% of the then outstanding common stock of Teletouch (assuming no additional issuances of common stock).

 In future filings the Company will seek to improve the disclosures cited by the staff to clarify the relationships between TLL Partners,
PCCI, PCI and RRI, and the direct and indirect holdings of each entity.

 SEC Comment:

 4. Further, refer to the last paragraph
of page F-13 and tell us why you reported a $36.4 million “gain” on preferred stock transaction on the face of your income statement given the related party nature of this transaction. Tell us your consideration of why you did not account
for this transaction as a recapitalization or reorganization without positive impact on your EPS. Explain also how you determined the amount of this “gain”. Give us your calculations and reconcile the values used for your common stock to
the trading market at the time of the exchange. We note that your shares traded as low as $0.11 per share in November 2002. Please refer to all pertinent authoritative accounting literature in your response.

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March 15, 2005

 Company Response:

Our response is divided into two sections, the first of which describes the transaction, and the second of which discusses our accounting conclusions.

 Description of the transaction

 The following, and the information included in Attachment 1, set forth the details of the
transactions.

 On May 17, 2002, TLL Partners, paid $800,000 and exercised an
option it had previously purchased to acquire all of the Teletouch securities held by Continental Illinois Venture Corporation (“CIVC”) which included $22,451,000 of the total $25,513,000 in outstanding principal and accrued interest under
the Junior Debt, 295,649 shares of Teletouch common stock, 2,660,840 warrants to purchase Teletouch common stock, 36,019 shares of Series B Preferred Stock, 324,173 warrants to purchase Series B Preferred Stock, and 13,200 shares of Series A
Preferred Stock.

 Pursuant to the Restructuring Agreement dated May 17, 2002 by
and among TLL Partners (which, as discussed above, is a related party), GM Holdings and Teletouch, TLL Partners and GM Holdings as the two holders of the Company’s Junior Debt reached an agreement that released and discharged Teletouch of its
Junior Debt obligations without recourse. GM Holdings forgave Teletouch’s debt obligations totaling $3,062,000 including accrued interest and TLL Partners forgave Teletouch’s debt obligations totaling $22,451,000.

 GM Holdings also granted TLL Partners, at no initial cost, an option to purchase all Series A
Preferred Stock and all Series B Preferred Stock held by GM Holdings. The exercise of the option would require Teletouch to issue to GM Holdings 6,000,000 common stock warrants to GM Holdings. Such warrants, when issued, were to be exercisable on
May 20, 2005 and redeemable at the option of the holder at $0.50 per share on May 20, 2007.

 Additionally, at the same time TLL Partners agreed it would sell Teletouch all of the GM Securities it might acquire as the result of the exercise of the option described above, as well as all of the common Stock,
common stock warrants, Series A Preferred Stock, Series B Preferred Stock and Series B Preferred Stock Warrants which TLL Partners held as the result of its previous purchase of those securities from CIVC, in exchange for 1,000,000 shares of
Teletouch’s Series C Preferred Stock.

 Teletouch received a fairness
opinion on this transaction from Hoak Breedlove Wesneski & Co. which established a value for the Series C Preferred Stock to be issued of $1,855,000 and a value on the 6,000,000 common stock warrants to be issued of $1,345,000. At the time of
the Fairness Opinion, the Company’s Common Stock was trading at $0.36 per share.

 Upon the forgiveness of the subordinated debt on May 20, 2002, the Company recorded a portion of the fair value of the Series C Preferred Stock and common stock warrants against the gain recorded on the extinguishment of the subordinated
debt. The fair value of the securities attributed to the extinguishment of the debt was 40% which was the pro rata carrying value of the debt ($25,513,000) versus the carrying value of the securities to be retired ($38,297,266). This allocation
resulted in a fair value allocation of $742,000 for the Series C Preferred Stock and $538,000 for the warrants to purchase common stock, as a reduction to the gain on extinguishment of debt. The gain recorded on the forgiveness of this debt was
$24,233,000 which was the $25,513,000 carrying value of the subordinated debt at that date less the above mentioned allocation of the fair value of the preferred stock and common stock warrants expected to be issued.

 On November 7, 2003 Teletouch’s shareholders approved the issuance of the Series C
Preferred Stock and the common stock purchase warrants. The securities held by TLL Partners were cancelled and returned to the Company and the 1,000,000 shares of Series C Preferred Stock and 6,000,000 common stock purchase warrants were issued to
TLL Partners and GM Holdings, respectively. As a result of this transaction, the Company compared the carrying value of the securities received with the

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March 15, 2005

remaining fair value of the securities issued (recall that a portion of the fair value of the Series C Preferred Stock and common stock warrants was recorded
in May 2002 against the gain on the extinguishment of the debt) as determined by the fairness opinion. This resulted in a net credit of $36.3 million (see calculations at Attachment 1).

 Accounting Treatment

 In reviewing the accounting literature prior to determining the accounting treatment for the preferred stock transaction, and the resulting
$36.3 million credit difference, we were advised to review the accounting treatment outlined in EITF D-42. We reviewed Topic EITF D-42 carefully, and noted that although the transaction directly addressed was one in which the fair value of the
consideration transferred to the holders exceeded the carrying amount of the preferred stock retired (i.e., a debit difference or loss), EITF Topic D-42 also included the statement that “Likewise, an excess of the carrying amount of preferred
stock over the fair value of the consideration transferred to the holders of the preferred stock would be added to net earnings to arrive at net earnings available to common shareholders. Accordingly, we accounted for the $36.3 million in the manner
set forth in EITF D-42.

 Our accounting for the transaction was discussed with
Ernst & Young, our independent accounting firm at the time, who reviewed it and agreed that our application of EITF Topic D-42 was appropriate in this instance.

 However, upon further review of the transaction and the related accounting literature, we now believe that the related party nature of the
transaction renders the application of EITF Topic D-42 inappropriate in these circumstances. Therefore, we now believe that the appropriate presentation is not to reflect the $36.3 million gain on the face of the income statement or include it in
the computation of EPS. In future filings we will remove the gain from the income statement and recompute our earnings per share for the period. The related disclosures in the notes to the financial statements will also be appropriately modified.

 SEC Comment:

 5. Also, see EITF topic D-42 and tell us why you characterized an excess of the carrying
amount of preferred stock over the fair value of the securities transferred as a “gain” on the face of your income statement given the capital nature of this transaction. In future filings, please re-characterize this line item and the
“Income (Loss)” caption above it to more clearly convey theft nature as net income and a capital exchange excess. Please refer to all pertinent authoritative accounting literature in your response.

 Company Response:

 See response to Comment 4. above. In all future filings, the Company will change the caption
from Income (Loss) to Net Income (Loss).

 SEC Comment:

 6. Similarly, in future filings, reposition the extraordinary item in
accordance with paragraph 11 of APB 30.

 Company Response:

 We have reviewed the reference guidance and in future filings we will
reposition the extraordinary item as follows:

 Income (loss) before income
taxes (benefit)

 Income tax expense (benefit)

 Income before
extraordinary items

 Extraordinary items

 Net Income

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March 15, 2005

 SEC Comment:

 7. Refer to the paragraph on page F-35, which indicates that you retained some of the paging infrastructure of Preferred Networks, Inc. (PNI). The disclosure in the last
paragraph of page 11, however, suggests that you applied paragraphs 44 and 45 of SFAS 141 to your purchase of PNI. Please advise. Tell us how you allocated the purchase price for PNI to the net assets that you acquired. Explain to us how you applied
SFAS 141 to this allocation and why it is appropriate to record an extraordinary item as a result of this transaction.

 Company Response:

 Teletouch acquired the assets of Preferred Networks, Inc. (PNI) on May 21, 2004 for total consideration of $257,467 (including legal and closing costs of $32,467). The
assets purchased were two distinct paging networks (the “North System” – New York and the “South System” – Georgia) including subscriber bases and the infrastructure assets. Additionally all of the furniture and
fixtures, vehicles, pager inventory, accounts receivable and spare network assets were acquired as part of this transaction.

 Simultaneous with the purchase, Teletouch entered into an agreement with another party to sell the North System and its customer base for $155,000.

 In applying the guidelines of SFAS 141, paragraph 44, we allocated the purchase price first
to the assets to be sold and the remaining current assets. The assignment of values to the assets to be sold, inventory and accounts receivable totaled $321,055 against a purchase price of $257,467, resulting in negative goodwill of $63,588. In
accordance with SFAS 141, paragraph 45, we reported the credit in the income statement as an extraordinary item for the period.

 SEC Comment:

 8. Refer to page F-6 and tell us how you complied with the guidance of SAB Topic 11B. Describe and analyze the “net book value of products sold” and “operating” expense line items. Tell us how much
of your depreciation and amortization expens