SecProbe.io

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Mail Stop 4561

      July 29, 2005

Mr. Christopher J. Floyd
Chief Financial Officer
Innovative Software Technologies, Inc.
100 North Tampa Street
Suite 2410
Tampa, FL 33602

      Re:	Innovative Software Technologies Inc.
		Form 10-KSB for the Year Ended December 31, 2004
		Filed May 5, 2005
		Form 10-QSB for the Quarter Ended March 31, 2005
		Filed May 23, 2005
		File No. 0-27465

Dear Mr. Floyd:

      We have reviewed your response letter dated June 27, 2005
and
have the following additional comments.  As previously stated,
these
comments require amendment to the referenced filings previously
filed
with the Commission.  Where indicated, we think you should revise
your documents 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 one of our comments, we 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
filings.
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 Year Ended December 31, 2004

Note 10 - Subsequent Events, pages F-19 - F-20

1. We acknowledge your response to prior comment 1.  We note that
you
believe that upon disposal of Triad Media, the goodwill on the
balance sheet at December 31, 2004 had no future utility or value.
In light of this fact, we are unclear why you used the trading
market
price of your common stock as opposed to the fair value of only
the
Triad Media reporting unit when performing step one of the
goodwill
impairment test described in paragraph 19 of SFAS 142.  Triad
Media
seems to be the reporting unit to which all of the remaining
goodwill
relates.  Additionally, please tell us why you did not test the
Triad
Media assets for recoverability at December 31, 2004 in light of
the
operating losses sustained in 2004 and its impending disposition.
Reference is made to SFAS 144, paragraph 8e & 8f.

Form 10-KSB/A for the Year Ended December 31, 2004 and Form 10-
QSB/A
for the Quarter Ended March 31, 2005

Exhibits 31.1 and 31.2

2. Please amend the certifications in Form 10-KSB/A and Form 10-
QSB/A
to conform the language in paragraphs 4, 4a, 4c, 5, 5a and 5b
exactly
to the corresponding language in Item 601 of Regulation S-B.
Additionally, please eliminate paragraph 6 as it is not included
within Item 601 of Regulation S-B.

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please file your response on EDGAR.  You may
wish
to provide us with marked copies of the amendment to expedite our
review.  Please furnish a cover letter with your amendment that
keys
your responses to our comments and provides any requested
information.  Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

      You may contact Matthew Maulbeck, Staff Accountant, at (202)
551-3466 or the undersigned at (202) 551-3403 if you have
questions.

								Sincerely,

      Steven Jacobs
      Accounting Branch Chief
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Mr. Christopher J. Floyd
Innovative Software Technologies
June 14, 2005
Page 1

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