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CORRESP
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[Precis Letterhead]

September 23, 2005

Via Federal Express and Fax
#202/772-9209

Mr. Daniel L. Gordon

Branch Chief

Securities & Exchange Commission

450 Fifth Street, N.W.

Washington, DC   20549

RE:          Precis,
Inc.; Form 10-K for the year ended December 31, 2004

                Filed
4/18/05; File No. 001-15667

Dear Mr. Gordon:

Thank you for your letter of September 12,
2005.  This will provide the responses of
Precis, Inc. (“the Company”) to your review of our Form 10-K for the year ended
December 31, 2004.  Our responses are
attached on Exhibit “A” to this letter.
Based upon your comments, it is our understanding that an amendment of
the Form 10-K is not required.  We thank
you for your thoughtful comments, as we strive to improve our reports to the
Commission and the public.

This will also confirm and acknowledge the
following:

•                  The Company is
responsible for the adequacy and accuracy of the disclosure in its filings
under the Securities & Exchange Act of 1934;

•                  staff comments
from the Commission or changes to disclosure in response to staff comments do
not foreclose the Commission from taking any action with respect to such
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.

Should you need any further information,
please feel free to contact me at 915-231-4239 or Bob Bintliff, our Chief
Financial Officer at 972-343-6501, or Eliseo Ruiz, III, our General Counsel, at
972-343-6500.

Very truly yours,

  /s/ Robert L. Bintliff

  Robert L. Bintliff

  Chief Financial Officer

Enclosures

cc:                             N. Zaffiris,
Chairman; F. Apodaca, President, CFO; E. Ruiz, III, V.P. & General Counsel;
M. Dunn (via fax  #405-945-0040)

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Exhibit
A

Precis,
Inc.

September
23, 2005

Results of Operations, page 32

  Comment:

  In future filings, please
  revise to provide a discussion of results of operations by segment. For
  reference, see item 303 of Regulation S-K.

  Response:

  The Company will provide,
  in future filings, discussions of results of operations by segment.

Consolidated Balance Sheet, page
F-4

  Comment:

  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.

  Response:

  The Company will separate
  deferred tax assets and liabilities into current and non-current portions,
  and will appropriately net those portions in future filings in accordance
  with paragraphs 41-42 of SFAS 109.

Consolidated Statement of
Operations, page F-5

  Comments:

  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.

  Response:

  We have confirmed that the
  amount of revenues related to the sales of products was .2% of revenue for
  2004.

Revenue Recognition, page F-8

  Comment:

  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.

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  Response:

  APB 22, paragraph 12
  states that “the disclosure should encompass important judgments as to the
  appropriateness of principles relating to recognition of revenue.”  The following disclosure represents our policy
  on revenue recognition for Access, in management’s view meets the criteria of
  ABP 22, and will be used in future filings: “The Company’s principal sources
  of service revenues include administrative fees for third party claims
  administration, network provider fees for the preferred provider network and
  utilization and management fees.  These
  fees are based on  monthly or per
  member per month fee schedules under specified contractual agreements.  Revenues from these services are recognized
  in the periods in which the services are performed and when collection is
  reasonably assured.”

Note 3 - Business Combination,
page F-11

  Comment:

  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’
  former shareholders.  To the extent
  that Access does not achieve the specified EBITDA levels during the
  contingency period, please negatively affirm in future filings.

  Response:

  Yes.  Access did achieve the stipulated EBITDA
  level for the year ended December 31, 2004.
  However, the calculated contingency consideration was immaterial
  ($1,147 cash and $1,147 in stock) and all parties agreed to combine it with
  the 1st quarter 2005 payment.  Contingent
  consideration was earned in each subsequent period and has been addressed in
  detail in quarterly reports and will be discussed in detail in future
  reports.

Note 10 - Income Taxes, page F-17

  Comment:

  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.

  Response:

  $760,681 is the $2,174,000
  NOL carryforward tax-effected amount using a tax rate of 35%.  In future filings, this distinction will be
  more clearly noted.

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