SecProbe.io

May 29, 2007

Mail Stop 4561

Mr. Mark Meller
President
Trey Resources, Inc.
5 Regent Street, Suite 520
Livingston, NJ  07039

Re: Trey Resources, Inc.
  Form 10-KSB for the ye ar ended Decem ber 31, 2006
Filed 4/9/07
File No. 000-50302

Dear Mr. Meller:

We have reviewed your filing and have the following comment.  Where indicated,
we think you should revise your document in response to this comment in future filings.
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
our comment, we may ask you to provide us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.

 Please understand that the purpose of our re view 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 comment or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Notes to Consolidated Financial Statements

Note 2 – Summary of Significant Accounting Policies

Revenue Recognition, page 15

1. Please elaborate upon your revenue recognition policy in future filings pursuant to
paragraph 12 of APB 22.  In a supplemen tal response, please pr ovide us with the
disclosure you will include in future filings and clarify how you determined that the policy complied with SAB 101.  Speci fically address how you account for the

Mr. Mark Meller
Trey Resources, Inc.
May 29, 2007 Page 2
resale of software when additional servi ces are provided as contemplated on page
5 of the Description of Business section and whether you account for the re-sale of software on a gross or net basis.

*    *    *    *

As appropriate, please respond to this comm ent within 10 business days or tell us
when you will provide us with a response.  Please submit a response letter on EDGAR
that keys your response to our comment and provides any requested information.
Detailed response letters greatly  facilitate our review.  Please understand that we may
have additional comments after revi ewing your response to our comment.

 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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed 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 comments, 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
filings;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

You may contact Kristi Ma rrone at (202) 551-3429 or me at (202) 551-3486 if
you have questions.

      S i n c e r e l y ,

Daniel L. Gordon
Branch Chief