SecProbe.io

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Mail Stop 6010

      June 21, 2005

Mr. William A. Ince
Chief Financial Officer
Integral Technologies, Inc.
805 W. Orchard Drive, Suite 3
Bellingham, Washington 98225

	RE:	Integral Technologies, Inc.
		Form 10-KSB for the fiscal year ended June 30, 2004
		Filed 10/05/04
		File No. 0-28353

Dear Mr. Ince:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
document
in future filings 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 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.

FORM 10-KSB for the period ending June 30, 2004

Item 8A Controls and Procedures, Page 9
1. We note your statement that your Chief Executive Officer and
Chief
Financial Officer believe that your existing disclosure controls
and
procedures have been effective. Please note that the effectiveness
determination required by Rule 13a-15(b) of the Exchange Act
cannot
only be based on the "belief" of your Chief Executive Officer and
Chief Financial Officer. Your management, with the participation
of
your principal executive officer and principal financial officer,
must evaluate the effectiveness of your disclosure controls and
procedures as of the end of each fiscal quarter, and must disclose
the results of each such evaluation in each periodic report. It
does
not appear that your certifying officers have reached a conclusion
that your disclosure controls and procedures are effective. Please
revise to address your officers` conclusions regarding the
effectiveness of your disclosure controls and procedures. Refer to
Rule 13a-15 of the Exchange Act and Item 307 of Regulation S-K.

Report of Independent Registered Public Accounting Firm, Page F-1

2. It is not clear whether your independent auditor Pannell Kerr
Forster of Vancouver, Canada is registered with the Public Company
Accounting Oversight Board ("PCAOB").  If true, please confirm to
us
that they are registered and have them revise the audit report
presented on page F-1 by signing the report utilizing their full
legal name as registered with the PCAOB.  If not, please explain
how
you comply with PCAOB Rule 1001.  We may have further comment
after
reviewing your response.

3. We see that your auditor is located in Canada and also see that
you are a domestic U.S. registrant.  The Staff interprets Article
2
to Regulation S-X to require that the audit report on the
financial
statements of a domestic registrant ordinarily be rendered by an
auditor licensed in the US. Tell us why you have selected an
auditor
located in Canada.  Please also respond to the following:
* Describe the nature and extent of any actual or planned
operations
in Canada.
* Tell us where your accounting records are maintained and where
your
audit work was completed.
* In Rule 3400T the PCAOB adopted, on an interim basis, the
quality
control standards of the SEC Practice Section.  Tell us who
performed
the US GAAP quality review of your financial statements and
describe
that person`s expertise in US GAAP and GAAS.
We may have further comments after reviewing your response.

*    *    *    *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that they
have
provided all information investors require.  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 in the filings reviewed by the staff 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.

      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 response that keys your
responses to our comments and provides any requested  information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

      You may contact Dennis Hult, Staff Accountant, at (202) 551-
3618 or myself if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3603 with any other questions.  In this regard, do not
hesitate
to contact Angela J. Crane, Accounting Branch Chief, at (202) 551-
3554.

							Sincerely,

							Jay Webb
							Reviewing Accountant

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William A. Ince
Integral Technologies, Inc.
June 21, 2005
Page 3

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