SecProbe.io

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       September 12, 2005

      Mail Stop 4561

Frank Apodaca
President
Precis, Inc.
2040 N. Hwy 360
Grand Prairie, TX  75050

      Re:	Precis, Inc.
		Form 10-K for the year ended December 31, 2004
      Filed 4/18/05
      File No. 001-15667

Dear Mr. Apodaca:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments in future filings.  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.

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Results of Operations, page 32
1. In future filings please revise to provide a discussion of
results
of operations by segment.  For reference see Item 303 of
Regulation
S-K.

Consolidated Balance Sheets, page F-4
2. We note that you present deferred tax assets and liabilities as
gross amounts and as non-current.  In future filings, please
revise
your presentation of deferred tax assets and liabilities to comply
with paragraphs 41 - 42 of SFAS 109 as necessary.  Specifically,
separate the deferred tax assets or liabilities into a current and
non-current portion and offset the amounts to the extent that the
assets and liabilities are for the same tax-paying component and
within the same tax jurisdiction.

Consolidated Statements of Operations, page F-5
3. We note that you present aggregated revenues from products and
services.  Please confirm to us that the amount related to product
sales represents less than 10% of total revenues or revise your
future filings to separately state revenue sources as instructed
by
Rule 5-03(b)(1) of Regulation S-X.  Please note that if you
present
revenues on a disaggregated basis, the related cost of revenues
should also be presented on a disaggregated basis.

Notes to Consolidated Financial Statements

Note 2 - Summary of Significant Accounting Policies

Revenue Recognition, page F-8
4. Refer to your policy on revenue recognition for Access third
party
administration.  In future filings this note should be revised to
describe your revenue recognition policies pursuant to paragraph
12
of APB 22.  In a supplemental response, please provide us with the
disclosure you will include in future filings and clarify how you
determined that the policy complied with SAB 101 if not readily
apparent.

Note 3 - Business Combination, page F-11
5. Advise us whether or not Access achieved the stipulated EBITDA
levels for the year ended December 31, 2004 that would result in a
contingent consideration payment to Access`s former shareholders.
To
the extent that Access does not achieve the specified EBITDA
levels
during the contingency period, please negatively affirm in future
filings.

Note 10 - Income Taxes, page F-17
6. You disclose that the Company had federal and state NOL
carryforwards of approximately $2,174,000 at December 31, 2004 and
2003.  Based on your deferred tax asset rollforward and balance
sheet
it appears that the NOL carryforwards only amounted to $760,681.
Please advise us and clarify in future filings.

*    *    *    *

      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 proposed revisions 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 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
Exchange Act of 1934 and 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Kristi Beshears at (202) 551-3429 or me at
(202) 551-3486 if you have questions.

						Sincerely,

Daniel L. Gordon
Branch Chief

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Precis, Inc.
September 12, 2005
Page 1

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