SecProbe.io

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                    Security Intelligence Technologies, Inc.
                   145 Huguenot Street, New Rochelle, NY 10801
                                  914-654-8700

                                                                     May 5, 2005

VIA EDGAR

Mr. John Hartz
Senior Assistant Chief Accountant
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

RE:      Security Intelligence Technologies, Inc.
              Form 10- KSB for the fiscal year ended June 30, 2004 Forms
              10-QSB for the quarters ended September 30 and
                     December 31, 2004
              Form 8-K filed March 24, 2005

              File No. 0-31779

Dear Mr. Hartz:

In response to the Commission's letter of comments dated April 11, 2005, we have
the following responses to the staff's comments:

FORM 10-KSB FOR THE YEAR ENDED JUNE 30, 2004

Distribution Agreement, page 3

1.       We note your response to prior comment 1. In future filings please
         disclose the annual minimum sales volume for the current year.

Registrant's Answer -For the information of the staff, the agreement, which is
dated April 14, 2004, provides that, after the first anniversary of the
agreement and for each year the agreement is in full force, the parties will
agree to annual minimum sales volumes, at a rate to be mutually determined after
the first 6 month anniversary of the Agreement. The parties have not yet set any
specific minimum purchase requirements for any year. In future filings we will
either disclose this fact or include any agreed-upon minimums.

Distribution Agreement, page 3

2.       We note your response to prior comment 2. It appears that sales under
         the distribution agreement accounted for 33% and 25% of total sales for
         the three and six months ended December 31, 2004. Since sales under
         this agreement appear to be material to the Company, in future filings
         please disclose the name of your supplier under the distribution
         agreement. For guidance, refer to paragraph (b)(5) of Item 101 of
         Regulation S-B, which requires the names of principal suppliers to be
         disclosed.

<PAGE>

Registrant's Answer - The supplier, a small Eastern European manufacturer, does
not want us to disclose its name. We do not believe that the identity of the
supplier is material. For the information of the staff, we are developing the
in-house capability of manufacturing and marketing a product which is
competitive with, and we believe superior to, the products we presently purchase
from the supplier. In this connection, we have established our own domestic and
European manufacturing capabilities and, once these facilities are established,
it will not be necessary for us to continue to use this supplier.

General Overview, page 15

3.       Please disclose in future filings the nature and status of this suit
         along with the amount of any accruals and when payment is expected to
         be made.

Registrant's Answer - The litigation, by the landlord of CCS' former New York
store, is against CCS, and we are neither a defendant in the action nor a
guarantor or party on lease. On March 22, 2005, we sold the stock of CCS. Since
our consolidated financial statements do not include the financial statements of
CCS, this claim is neither our liability nor our contingent liability.

Joint Venture Agreements, page 17

4.       In future filings, please disclose why the joint ventures have not
         generated any revenues as of June 30, 2004 and when you expect this to
         change.

Registrant's Answer - For the information of the staff, because of our financial
condition, we did not have any available capital to fund the joint venture, and
the other party was not willing to make an investment. We are reviewing our
joint ventures on a regular basis to determine whether we wish to continue any
of them, since we do not anticipate that we will be able to provide any funding
to any of these joint ventures until and unless our business generates
sufficient cash flow form operation to justify such an investment. If we decide
to continue to refer to the joint ventures in our filings with the Commission,
we will include this disclosure. We may, however, eliminate any reference to the
joint ventures to the extent that they are inactive and generate neither revenue
nor liabilities.

Revenue Recognition, page 38

5.       We note your response to prior comment 11. Please revise your disclose
         in future filings to address when revenue is recognized on your
         sophisticated monitoring systems that sometimes include installation
         and testing.

Registrant's Answer - We will disclose when revenue is recognized on our
sophisticated monitoring systems that sometimes include installation and testing
in future filings. For the information of the staff, we recognize revenue from
our sophisticated monitoring systems after installation, testing and customer
acceptance.

<PAGE>

Accounting Controls

6.       We note your response to prior comment 15. As part of your previous
         response you noted your independent auditors identified a weakness in
         your financial reporting. In light of this identified weakness, please
         tell us how you determined that your disclosure controls and procedures
         were nonetheless effective at year end. Refer to Release 33-8238 for
         guidance.

Registrant's Answer - Although we do not have a person to review the work of the
chief financial officer, we utilize checklists, including a U.S. GAAP financial
statement disclosure checklist, a SEC financial statement disclosure checklist
and a Sarbanes Oxley financial statement disclosure checklist to make sure that
all transactions to which we are a party are properly reflected and that all of
our corporate assets are properly maintained by us in our name. These checklists
are reviewed on a quarterly and annual basis by both the chief executive officer
and the chief financial officer and are reviewed by our independent auditors. In
connection with their annual audit, our independent auditors, who are aware of
the absence of checks and balances, review our books and records in a manner
which enables them to give an opinion that are financial statements reflect, in
accordance with GAAP, our financial condition on the respective balance sheet
dates and the results of our consolidated operations and our consolidated cash
flows for the period then ended in accordance with GAAP. The auditor's report
does not include any qualification resulting from the absence of checks and
balances. As a result, we believe that our disclosure controls are effective.

FORM 10-QSB FOR THE QUARTER ENDED DECEMBER 31, 2004

Description of business

7.       We note in your December 31, 2004 Form 10-QSB that you have re-focused
         your marketing efforts on your bomb jamming and cellular monitoring
         systems. In future filings please provide a description of these
         services.

Registrant's Answer - We will provide a description of these products in future
filings.

Professional Fees and Legal Matters

8.       We note that you have payables for professional fees and legal matters
         of $1.4 million as of December 31, 2004. Please tell us the amount, if
         any, that relate to unpaid audit fees and the period related to the
         unpaid fees.

Registrant's Answer - At December 31, 2004 we had unpaid audit fees of $31,213
all related to the audit of the June 30, 2004 financial statements. These fees
were paid on January 20, 2005. There was no significant amount due to our
independent auditors at June 30, 2004.

<PAGE>

Note 10 - Subsequent Events, page 13

9.       It appears that shareholder approval is required for your 2005 stock
         plan per your disclosure in Note 10. In future filings please disclose
         when you expect to obtain shareholder approval.

Registrant's Answer - The 2005 Stock Plan does not require stockholder approval
unless we grant incentive stock options. We have no present plans to seek
shareholder approval of the plan and will disclose that in future filings,
although we may present the plan to the stockholders for their approval at the
next annual or special meeting.

General

10.      We note your corporate location is in Rochelle, New York. Please tell
         us whether your current auditors are licensed to practice in New York.

Registrant's Answer - Our current auditors are licensed to practice in New York.

FORM 8-K FILLED MARCH 24, 2005

General

11.      Please provide the staff with the Company's analysis of the application
         of its reporting under SFAS 144. Please refer to paragraphs 41- 46 of
         SFAS 144.

Registrant's Answer - We believe we meet all of the conditions of SFAS 144,
paragraph 41 - 46 to treat the results of operations of the disposed entity as a
discontinued operation.

Paragraph 41. The operations of CCS can be clearly distinguished, operationally
and for financial reporting purposes from the rest of our operations. CCS'
operations consisted of the operation of retail stores. Although modest retail
sales were made from our headquarters and London office, our accounting and
other records for the retail stores enable us to break out those operations from
the balance of our operations.

Paragraph 42. As a result of the sale of CCS, the business operations and the
cash flow from CCS are no longer a part of our operations, and we have no
continuing involvement in the operation of CCS's retail stores or otherwise.

Paragraph 43. Commencing with our financial statements for the quarter and nine
months ended March 31, 2005 (and the comparable periods of 2004), we will
reflect the discontinued operations as required by Paragraph 43.

Paragraph 44. The financial statements for the quarter and nine months ended
March 31, 2005 will reflect any additional costs associated with the sale of
CCS. Although not a cost, since we guaranteed CCS' obligations to Mr. Jamil, we
are treating those obligations as if they were our direct obligations. This
classification is disclosed in the Form 8-K.

Paragraph 45. The gain or loss, if any, on the sale of the CCS stock will be
reflected as a separate line item.

<PAGE>

Paragraph 46. The assets of CCS will be reflected as assets of discontinued
operations. We do not believe that it is appropriate to classify them as assets
held for sale.

12.      Please advise the staff whether the company expects to secure
         substantive services from Menahem Cohen under the terms of the
         consulting agreement with him.

Registrant's Answer - We expect to receive substantive services from Menahem
Cohen under the terms of our consulting agreement with him. We anticipate that
Mr. Cohen, who was actively involved in marketing our products before he
purchased CCS, will continue to provide senior-level marketing services.

                                     * * * *

We understand we are responsible for the accuracy and adequacy of the disclosure
in the filings reviewed by the staff and endeavor to be certain that they have
provided all information investors require. Since we are in possession of all
facts relating to a company's disclosure, we are responsible for the accuracy
and adequacy of the disclosures we make.

We acknowledge that the company that:

     o    the company is responsible for the adequacy and accuracy of the
          disclosure in their filings;

     o    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

     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.

In addition, we have been advised that the Division of Enforcement has access to
all information we provide to the staff of the Division of Corporation Finance
in their review of our filing or in response to their comments on our filing.

If you have any questions, please do not hesitate to contact Chris R. Decker,
Chief Financial Officer at (914) 654-8700, ext. 228.

                                                    Very truly yours,

                                                    /s/: Ben Jamil
                                                    Ben Jamil
                                                    Chief Executive Officer

                                                    /s/: Chris R. Decker
                                                    -------------------------
                                                    Chris R. Decker
                                                    Chief Financial Officer

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