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Concierge Technologies Correspondence 5-2-05

FULLER, TUBB, POMEROY & STOKES

A PROFESSIONAL CORPORATION

ATTORNEYS AT LAW

201 ROBERT S. KERR AVENUE, SUITE 1000

OKLAHOMA CITY, OK 73102

      G.
      M. FULLER (1920-1999)

       TELEPHONE 405-235-2575

    JERRY TUBB

      FACSIMILE 405-232-8384

    DAVID POMEROY

      TERRY
      STOKES

         ______

      OF
      COUNSEL:

      MICHAEL
      A. BICKFORD

          THOMAS J. KENAN E-MAIL:

      THOMAS
      J. KENAN

             kenan@ftpslaw.com

      ROLAND
      TAGUE

      DAN
      M. PETERS

May 2, 2005

Cicely
D. Luckey, Senior Staff Accountant

Division
of Corporation Finance

Mail
Stop 09-09

U.S.
Securities and Exchange Commission

Washington,
DC   20549

ATTENTION
YOLANDA CRITTENDO, STAFF ACCOUNTANT

Re:
Concierge Technologies, Inc.

File No. 000-29913

Form 10-KSB for the year ended June 30, 2004

Form 10-QSB for the period ended September 30, 2004

Dear
Ms. Luckey:

With
further regard to your letter of February 16, 2005 containing four comments with
respect to the referenced filings, please be advised as follows:

Form
10-KSB

Financial
Statements and Notes

Note
10 - Subscriptions for Common Stock Subject to Contingency, page 23

1.
We have supplementally furnished the staff a copy of the company’s attorney’s
opinion letter, the effect of which is that subsequent to December 31, 2004 all
contingencies have been removed by the passage of time and the application of
applicable statutes of limitations.

Note
16 - Acquisition, page 26

2.
The Company acquired a technology in the development stage. The technology had
no commercial value at the time of acquisition since it was in process of
development. The technology had no market value at the time of the acquisition.
Therefore consideration paid was allocated towards goodwill, cash and net
property and equipment.

Cicely
D. Luckey

May
2, 2005

Page
2

3.
The Company acquired a technology in the development stage. Therefore
consideration paid was allocated towards goodwill, cash and net property and
equipment. The Company recorded goodwill on acquisition. The impairment is for
the goodwill recognized at the time of acquisition and not for the technology
acquired in the development stage. (See response to Note 13 below for the Form
10-QSB for 12-31-04.)

4.
On April 6, 2004, the Company entered into a Stock Purchase agreement with
Planet Halo. Upon acquisition of Planet Halo, the Company recorded a goodwill
amounting $496,843.

On
December 31, 2004, the Company evaluated the goodwill for impairment, as the
circumstances indicated that the carrying value may not be recoverable from the
estimated future cash flows of Planet Halo. The Company measured the goodwill by
comparing its net book value to the related undiscounted cash flows from the
reporting unit, i.e., Planet Halo, considering a number of factors
including past operating results of Planet Halo, budgets, economic projections,
market trends and product development cycles. Based upon these facts, the
Company determined the goodwill is impaired and recorded the impairment of
$496,843 in the financial statements.

We
understand that the Company is responsible for the adequacy and accuracy of the
disclosure in the filing. Further, we acknowledge that 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.

Please
contact the undersigned should additional information be needed.

Sincerely,

/s/
Thomas J. Kenan

Thomas
J. Kenan

cc:
David Neibert, CEO of Concierge Technologies, Inc.

Hamid Kabani, C.P.A.