SecProbe.io

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                       [Letterhead of Jackson Walker, LLP]

January 11, 2005

Ms. Tamara Tangen, CPA
Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C.  20549

Re:      iLinc Communications, Inc.
         Response to SEC Letter dated December 28, 2004 concerning Form 8-K
         filed December 20, 2004 concerning change in accountants and Form 10-Q
         for the quarter ended September 30, 2004
         File No. 001-13725

Dear Ms. Tangen:

         On behalf of iLinc Communications, Inc. ("iLinc" or the "Company"),
this letter is in response to the comments contained in the Staff's letter of
December 28, 2004 (the "Comment Letter") regarding the above filings.

     The following responses indicate, where appropriate, the additions and/or
revisions that have been made to the Company's Form 8-K and Form 10-Q in
response to your Comment Letter. The responses are numbered to correspond to the
numbers assigned to each comment in your Comment Letter. Capitalized terms used
in this response letter, but not defined herein, have the meaning assigned to
those terms in the respective filings. I have included a copy of the respective
amended filings with the changes to Item 4 of the 10-Q and Item 4.01 of the 8-K
marked for your review.

     FORM 8-K CONCERNING CHANGE IN ACCOUNTANTS

     1.   We requested the modification of the filing via fax to Filer Support
          to indicate that the exhibit listed under Item 9.01 is also being
          reported under Item 4.01. A copy of our request letter is attached for
          your convenience.

     2.   We have authorized the Company's former accountant to respond fully to
          the inquiries of the successor accountant concerning the subject
          matter of the material weakness and have incorporated that
          authorization into an amended Form 8-K, a copy of which is attached,
          with the document marked to show changes from the Form 8-K filed
          December 20, 2004.

     3.   We have obtained an updated letter from our former accountants
          indicating that they agree with the statements contained in the
          Company's amended 8-K, a copy of which is attached to the amended Form
          8-K as Exhibit 16.

     FORM 10-Q FOR PERIOD ENDING SEPTEMBER 30, 2004

     4.   We have revised Item 4 of the Company's Form 10-Q for the quarter
          ending September 30, 2004 to clarify the statements regarding the
          conclusions made by our principal executive officer and of our
          principal financial officer. A copy of Form 10-Q/A is attached with
          the document marked to show changes to Item 4 from the Form 10-Q
          originally filed.

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     5.   We have revised Item 4 of the Company's Form 10-Q for the quarter
          ending September 30, 2004 to clarify the statements concerning the
          design of disclosure controls and procedures. A copy of Form 10-Q/A is
          attached with the document marked to show changes to Item 4 from the
          Form 10-Q originally filed.

     6.   The material weakness referenced in the Company's Form 10-Q for the
          quarter ended September 30, 2004 dealt specifically with discovery
          during the quarterly review process of changes that occurred during
          the quarter ended September 30, 2004 to the Company's standard form of
          software license agreements that affected the basis for revenue
          recognition under those contracts. Subsequent to quarter end, a
          confirmation received by the Company's former auditor revealed that
          the Company's standard software license agreement had been changed by
          the sales department to provide for a 30-day to 90-day trial period
          during which the customer could use the i-Linc product and decide
          whether or not to purchase it, but that this change had not been
          communicated effectively to the accounting department.

          Upon discovery of this change, the Company's accounting department
          instituted a search of all customer contracts for all prior periods
          and interviewed the sales staff to determine if modifications had ever
          occurred in the past to any standard software license agreement. They
          found that during the quarter ended September 30, 2004 five (5)
          standard software license agreements entered into by the Company
          during that quarter had been modified to include the previously
          discussed "trial period" concept. Having discovered the new trial
          period language, the accounting group appropriately deferred the
          revenue associated with those sales until the expiration of the trial
          period. The modifications required deferral of $103,150 in license
          revenue to subsequent periods beyond September 30, 2004.

          The discovery of the change to the Company's standard form of software
          license occurred before final preparation and filing of the Company's
          financial statements reflected in the Company's Form 10-Q for the
          quarter ended September 30, 2004. Therefore no correction or
          restatement of the Company's financial statements was necessary or
          warranted. The total revenue associated with all of the modified
          agreements was $103,150, and all of that revenue was deferred and may
          be recognized in future periods, as appropriate and in accordance with
          GAAP.

          The Company has implemented steps to prevent failure to communicate
          changes in standard forms of customer contracts in the future and
          strengthen the Company's internal controls related to contract
          management and its impact on revenue recognition. The Company has put
          procedures into place to prevent modification of its standard form of
          software license agreements without due and proper notice to all
          parties, including the Company's accounting group. Those steps to
          correct and prevent this in the future include, new controls over the
          modification of electronic contracts adding limited password
          protection, the electronic receipt of contracts from customers
          directly to both the sales and accounting groups simultaneously, the
          numbering of contracts and order forms to provide a stronger audit
          trail, the electronic storage of all customers' contracts providing
          real-time access, the notification of the accounting department by the
          sales or legal departments should modification occur, and remedial
          training of the sales group on the impact of changes to the software
          license agreement. A further segregation of duties was also
          implemented to better control contract workflow. A supervisor from the
          sales team must approve all sales orders before they are accepted by
          the sales department, and a supervisor from the accounting group must

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          approve all orders that exceed $10,000 in amount before they are
          accepted as a valid sale of the company. An order processing clerk
          verifies that the appropriate Customer and Company authorizations have
          been obtained. The approved sales order is transmitted to the customer
          service department for order fulfillment. Notification of fulfillment
          of the order is sent to both the sales and accounting departments.
          Before revenue is recognized on any sales order, the controller
          verifies that the sales order was properly approved by the customer
          and the Company, verifies that changes, if any, to the standard
          license agreement have been properly documented in writing and in the
          customer's electronic file and thereafter records revenue based upon
          the approved and verified documentation.

          The Company's prior accountant was made aware of the changes made in
          the Company's contract management internal control, but has not
          reviewed or performed testing given the change in accountants that
          occurred subsequent to the period end.

     7.   The communication concerning the material weakness was communicated
          orally by the prior accounting firm to the Company's audit committee
          and to the Company's management. The former accountants provided no
          letter or written communications to the Company's management or Audit
          Committee regarding any disagreements or reportable events.

     The Company acknowledges that:
     o    The Company is responsible for the adequacy and accuracy of the
          disclosure in the filings of the Company, including those amended and
          attached hereto;
     o    The Staff comments or changes to disclosure in response to the staff
          comments do not foreclose the Commission from taking any action with
          respect to the filing; and,
     o    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.

This supplemental information is being filed as correspondence on EDGAR. We
would appreciate the Staff's prompt attention to this response and please direct
any further questions to me, Jim Ryan of Jackson Walker, L.L.P. at (214)
953-5801.

Very truly yours,

/S/ James S. Ryan, III
----------------------
James S. Ryan, III

Enclosure

cc:      James L. Dunn, Jr.
         iLinc Communications, Inc.
         Sr. Vice President & General Counsel

---------------
James L. Dunn, Jr.

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