SecProbe.io

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Mail Stop 4561

      							August 4, 2005

Mr. Richard Govatski
Chief Executive Officer
NMXS.Com, Inc.
5021 Indian School Road
Suite 100
Albuquerque, New Mexico 87110

	Re:	NMXS.Com, Inc.
		Form 10-KSB for the Fiscal Year Ended December 31, 2004
      Form 10-QSB for the Fiscal Quarter Ended March 31, 2005
      File No. 333-30176

Dear Mr. Govatski:

		We have reviewed the above referenced filings and have
the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  We may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  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 Fiscal Year Ended December 31, 2004

Item 7.  Financial Statements

Report of Independent Registered Public Accounting Firm, page F1

1. We note that the audit opinion expressed in the report of
independent registered public accounting firm on page F1 indicates
that it is for each of the two years in the period ended December
31,
2004.  We further note that the audit opinion of your former
independent registered accounting firm for the year ended December
31, 2003 has been included on page F2.  Clarify why you have two
audit opinions for the year ended December 31, 2003.

Notes to Consolidated Financial Statements

Note B - Summary of Significant Accounting Policies

[2] Revenue Recognition, page F7

2. Your disclosure indicates that your sales arrangements may
contain
elements for software, maintenance, third party hardware and
software, consulting services and licenses.  For each type of
multiple element arrangement, tell us whether you have established
vendor-specific objective evidence (VSOE) of fair value to
allocate
the arrangement fee to the individual elements of your
arrangements.
If you have established VSOE of fair value, tell us how your
accounting complies with SOP 97-2, paragraph 10, including SOP 98-
9.
Further, tell us what consideration you gave to disclosing your
policy for allocating the arrangement fee to multiple elements in
accordance with SAB Topic 13.B Question 1.

3. Your disclosure on page 12 indicates that software maintenance
includes hosting services.  In these arrangements that contain
hosting services, clarify whether your customers have the right to
take possession of the software products and whether it is
feasible
for the customer to run the software on its own.  Tell us how you
consider EITF 00-3, paragraphs 5 and 6, when determining whether
your
arrangements that contain hosting services are within the scope of
SOP 97-2.  In this regard, tell us how you account for and how
your
disclosure addresses software arrangements that include hosting
services and those that do not, and the authoritative literature
that
you apply.

4. We note that some of your arrangements involve custom software
development that requires you to provide significant production,
customization or modification services.  Your disclosure in the
notes
to financial statements indicates that you recognize custom
software
development services separately from the software and recognize
the
custom software development services using percentage of
completion.
We further note your disclosure in Critical Accounting Policies
and
Estimates on page 13 that for custom software development
arrangements both the product license and consulting services
revenue
are recognized together as work progresses.  Please reconcile
these
statements by indicating whether the services are accounted for
separately from the software.  If services are accounted for
separately, tell us how you meet the criteria discussed in
paragraph
65 of SOP 97-2.  Further, clarify whether you measure progress to
completion under the percentage of completion method using labor
hours as disclosed on page 13 or specific milestones as disclosed
on
page F7.  Tell us how you have considered paragraphs 78 through 91
of
SOP 97-2 when determining the appropriate measure to use for your
arrangements.
5. We note from page 13 that you recognize revenue, in part, when
the
determination that collection of a fixed or determinable fee is
reasonably assured.  Tell us whether collection must be probable
in
order to recognize revenue in accordance with paragraph 8 of SOP
97-
2.  We further note, based on your disclosure on page 19, that you
offer extended payment plans in some of your arrangements.  Tell
us
how you consider collectibility in determining whether revenue
should
be recognized and paragraphs 26 through 29 of SOP 97-2 when
determining whether your arrangement fee is fixed and
determinable.

6. We note on page 19 and page 10 of your Form 10-QSB for the
quarter
ended March 31, 2005, that you have recognized revenue from barter
transactions.  Tell us the non-monetary assets that you transfer
in
your barter transactions and how you determine fair value of these
assets.  Clarify how you have considered the provisions of
paragraphs
25 and 26 of APB 29 and EITF 93-11 when accounting for your barter
transactions.  Further describe your policy for recognizing the
expense for the advertising or other non-monetary assets that you
receive in the transactions.  Also, tell us how you have
considered
the disclosure requirements of paragraph 28 of APB 29 for your
barter
transactions.

Item 8A. Disclosure Controls and Procedures, page 41

7. Your disclosure states that "under the supervision and with the
participation of management, as of September 30, 2004, the
Certifying
Officers evaluated the effectiveness of the design and operation
of
our disclosure controls and procedures".  We further note your
disclosure on page 24 of your Form 10-QSB for the quarter ended
March
31, 2005 that states "under the supervision and with the
participation of management, the Certifying Officers evaluated the
effectiveness of the design and operation of our disclosure
controls
and procedures within 90 days prior to the filing date of this
report."  Item 307 of Regulation S-B and Rule 13a-15(b) require
that
the effectiveness of disclosure procedures and controls be
assessed
as of the end of the period covered by the report.  Revise
accordingly.

8. We note your disclosure that you "have not made any significant
changes to [y]our internal controls subsequent to the date of the
Evaluation Date."  We also note a similar  disclosure in your Form
10-QSB for the quarter ended March 31, 2005 in which you indicate
that there were no significant changes in your internal controls
or
other factors subsequent to the date of your officer`s evaluation.
Consistent with the evaluation required by Rule 13a-15(d) of the
Exchange Act, please revise to definitively state whether there
has
been any change in your internal control over financial reporting
identified in connection with your evaluation that occurred during
the period that has materially affected or is reasonably likely to
materially affect your internal control over financial reporting.
See Section II.F.4 of Release No. 33-8238 for additional guidance.
*****

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please submit all
correspondence on EDGAR as required by Rule 101 of Regulation S-T.
Please understand that we may have additional comments after
reviewing your response to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes 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.

	In connection with responding to our comment, 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 filing;

* staff comments or changes to disclosure in response to staff
comments 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.

	You may contact Christopher White, Staff Accountant, at (202)
551-3461, Melissa Walsh, at (202) 551-3224 or me at (202) 551-3488
if
you have any questions regarding our comments on the financial
statements and related matters.

								Sincerely,

								Stephen Krikorian
								Accounting Branch Chief

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Mr. Richard Govatski
NMXS.Com, Inc.
August 4, 2005
page 1

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