SecProbe.io

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[ innovative
   software
 technologies
    logo ]
                                          Innovative Software Technologies, Inc.
                                            100 North Tampa Street, Suite 2410
                                                    Tampa, Florida 33602
                                                    Phone: (813) 387-3310
                                                     Fax: (813) 387-3311
--------------------------------------------------------------------------------

June 27, 2005

Steven Jacobs
Matthew Maulbeck
Division of Corporate Finance
Securities and Exchange Commission
Washington, D.C. 20549
Mail Stop 4561

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

Gentlemen:

This letter is in response to your comments to the company of June 14, 2005.

Form 10-KSB for the Year Ended December 31, 2004

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

Question  No. 1:  Please  explain how you  concluded  that the Triad Media asset
group was not impaired at December 31, 2004 under SFAS 142 and SFAS 144.  Please
refer to paragraphs 8 and 29 of SFAS 144 and paragraph 17 of SFAS 142.

We performed our annual impairment  reviews in accordance with SFAS 142 and SFAS
144 as of December 31, 2004. Due to the impending disposition of Triad Media, we
reevaluated  the  long-lived  assets and goodwill for impairment as of March 31,
2005.

We evaluated  the carrying  value of goodwill on each of the above dates,  using
the two step  approach set forth in paragraphs 19 and 20 of SFAS 142. As of each
date, we passed the first test of non-impairment, using the trading market price
of our common stock for fair value measurement.

Paragraph 39 of SFAS 142 provides that  goodwill of the reporting  unit shall be
included in the carrying amount of the reporting unit in determining any gain or
loss on  disposal.  We believe that upon  disposal of Triad Media,  the goodwill
will  have no  future  utility  or value  and,  as  reflected  in our pro  forma
presentations, reflect the goodwill as a charge to operations upon disposal.

<PAGE>

[ innovative
   software
 technologies
    logo ]
                                          Innovative Software Technologies, Inc.
                                            100 North Tampa Street, Suite 2410
                                                    Tampa, Florida 33602
                                                    Phone: (813) 387-3310
                                                     Fax: (813) 387-3311
--------------------------------------------------------------------------------

As mentioned,  we considered the future  recoverability  of tangible  long-lived
assets of Triad Media,  consisting of a minimal amount of office  equipment,  at
December  31,  2004 and again at March 31,  2005.  We did not  believe  that any
conditions set forth in paragraph 8 a-f of SFAS 144 were present at those dates.
We noted that  paragraph 29 of SFAS 144 provides  that a long-lived  asset to be
disposed  of in  an  exchange/spinoff  is  disposed  when  it  is  exchanged  or
distributed.  Accordingly, we plan to account for the disposition of Triad Media
in our second quarter,  which is when management and our board made the decision
on the disposition.

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

Question  No. 2:  Please  amend  Form  10-KSB  and Form  10-QSB to  conform  the
certifications in exhibits 31.1 and 31.2 to Item 601 of Regulation S-B.

Based upon your observations,  we compared our  certifications  with the form of
certification  set forth in Item 601 of Regulation  S-B. We have  concluded that
the exhibits  require  amendment for item 4 (c) of the form of  certification in
Item 601 which  corresponds  to our item 4 (b).  Each  referenced  certification
should be amended, as follows:

      "4  (b)  Evaluated  the  effectiveness  of  the  small  business  issuer's
      disclosure  controls  and  procedures  and  presented  in this  report our
      conclusions  about  the  effectiveness  of  the  disclosure  controls  and
      procedures,  as of the end of the period  covered in this report  based on
      such evaluation."

Per our discussion,  we will file the amended  certifications  on Forms 10-KSB/A
and 10-QSB/A, without refilling the entire documents.

Innovative Software  Technologies,  Inc. acknowledges that it is responsible for
the adequacy and accuracy of the disclosure in the filings,  that staff comments
or changes to  disclosure  in response to staff  comments do not  foreclose  the
Commission  from taking and action with respect to the filings,  and that it 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.

Sincerely,

/s/ Christopher J. Floyd
------------------------
Christopher J. Floyd
Chief Financial Officer

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