SecProbe.io

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February 16, 2005

Fax (202) 942-9635
Mail Stop 04-09

David Neibert, President
Concierge Technologies, Inc.
22048 Sherman Way, Suite 301
Canoga Park, CA 91303

Re:	Concierge Technologies, Inc.
	File No.    000-29913
      Form 10-KSB for the year ended June 30, 2004
      Form 10-QSB for the year ended September 30, 2004

Dear Mr. Neibert:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB

Financial Statements and Notes

Note 10 - Subscriptions Received for Common Stock Subject to
Contingency, page 23
1. We noted that should no exemption from registration have been
available with respect to the sale of the post merger shares, the
persons who bought them would be entitled to the return of their
subscription amounts if actions to recover such monies should be
filed within one year after the sales in question.  Given the fact
that one year has elapsed since the sale of these shares, please
clarify the nature of the ongoing contingency relating to this
issue.
Similarly clarify what continued exposure you have regarding the
contingent Concierge shares.  At what point are these
contingencies
likely to be resolved?

Note 16 - Acquisition, page 26
2. Reference is made to your disclosures on page 4 under the
section
entitled "Patents, Trademarks, Copyrights and Intellectual
Property".
Upon acquiring Halo, we note that you acquired certain trademarks
and
intellectual property, yet the majority of the purchase price was
assigned to goodwill.  What consideration did you give to
assigning
values to these potential intangible assets in your purchase price
allocation?  To the extent the intellectual property has no
alternative future use, how did you consider the guidance in
paragraph 42 of SFAS 141.
3. Advise us supplementally and consider expanding your future
filings to clarify your accounting policy for assessing goodwill
for
impairment.
4. Tell us how you complied with Rule 310 (c) and (d) of
Regulation
S-B in determining whether to include audited financial statements
of
Planet Halo and pro forma financial information showing the
effects
of the acquisition.

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental 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 reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 Yolanda Crittendon at (202) 942-1868 or me at
(202) 942-1975 if you have questions regarding comments on the
financial statements and related matters.

Sincerely,

Cicely D. Luckey
Senior Staff Accountant

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Concierge Technologies, Inc.
Page 1

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