SecProbe.io

Mail Stop 4561
       June 5, 2007

Joseph P. Coschera
Chief Executive Officer
Information Systems Associates, Inc.
2120 SW Danforth Circle
Palm City FL 34990

 Re:  Information Systems Associates, Inc.
  Registration Statement on Form SB-2
  Filed on April 27, 2007
  File No. 333-142429

Dear Mr. Coschera:

     We have reviewed your Form SB-2 a nd have the following comments in addition to the
comments relating to the financial statements that  were issued in our letter dated May 24, 2007.
Where indicated, we think you should revise your doc ument 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 some of our comments, we
may ask you to provide us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not raise additional comments.

      Please understand that th e purpose of our review process is  to assist you in your compliance
with the applicable disclosure requirements and to enhance the ove rall disclosure in your filing.
We look forward to working with you in these re spects.  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.

General
1. We note that you identified the initial filing as an amendment using the heading “SB-2/A”
on the facing page.  Please ensure that each  amendment to the initial filing is properly
identified using the heading.  In this regard, your next ame ndment should be identified as
Amendment No. 1 to Form SB-2.

Summary Information and Risk Factors, page 5
2. Please clarify whether you develop, package or market any of the elements of your product
and services suite or whether your offerings ar e those of third parties, which you supply to

Joseph P. Coschera
Information Systems Associates, Inc.
June 4, 2007
Page 2

customers.  We note your statement on page 27 that Information Systems Associates is a
Value Added Reseller.  To the extent your VAR status describes the majority of your core
activities, this should be clearly described.  In addition, identify more specifically what
products and services you offer.  Please note that where the comments regarding the
summary section relate to the disclosure in  the business section, appropriate revisions
should be made in that section as well.
3. We note your inclusion of numerous acronyms on page 5 of the summary.  For example, you refer to EAM, NCCI, CMMS, EAM, ERP, RO I, ROA.  Please recall that the summary
section is subject to the pl ain English principles and th e unnecessary use of acronyms is
discouraged.  Further, your continued use of  acronyms throughout the prospectus, such as
KPIs, MTTR, OSPI, and VNDI, for example, app ears to be avoidable.  Please revise
throughout the prospectus to eliminate as much  as possible your reliance on acronyms.
4. We note your list of customers.  Disclose th e criteria you used in se lecting the customers
you identified by name both here and in the business section.  Is there a minimum dollar
value of sales you made to the companies you list, for example?  We find no discussion elsewhere that you have any customers or gr oup of customers who account for more than
10% of your revenues as of fiscal year end. Advise of the total percentage of revenues
generated from each of the listed customers durin g the last fiscal year and most recent
interim period and confirm that the customers listed are current customers.
5. Please include a brief background discussion of Aperture and th e nature of your partnership
relationship with Aperture.  In  this regard, we note your brief summary of the relationship
on page 22.  To the extent you have a contr actual agreement with Aperture governing your
partnership, please tell us what consideration you gave to fi ling it as an exhibit to the
registration statement.  See Item 601(b)(10) of Regulation S-B.
6. Describe in greater detail the “F acilities solutions” you offer.
7. Under Offering, please explain why you have included a parenthetical “assumes no broker-
dealers are paid a commission” regarding proc eeds to Information Systems Associates. In
this regard, we note that this is a sell ing shareholder initial  public offering.

Risk Factors, page 8
8. Please revise the introductory para graph to clarify that the risk factors listed constitute the
material risks facing the company.  Your refere nce to “certain” risks and your statement that
the listing is not intended to be exhaustive may suggest that there are risks the company
considers to be material that are not include d.  The risk factors should include all known
material risks to the company.  See Item  503 of Regulation S-B.  Please revise.
9. In addition, please remove the third sentence advising potential investor s to read the risk
factors in conjunction with othe r cautionary statements made in  the registration statement,

Joseph P. Coschera
Information Systems Associates, Inc.
June 4, 2007
Page 3

other public reports, annual re ports and public announcements.  The risk factors should be
self-contained and readers shoul d not be required to look to  other documents to understand
the full meaning of the risks you discuss.

There is a risk that our shares may not become quoted on the Over-the-Counter Bulletin Board,
page 9
10. Please revise the risk factor subheading to state the risk more clearly from the point of view
of the potential investor.  It would appear that the primary ri sk to investors if your shares are
not quoted on the OTCBB and are ultimately quo ted on the pink sheets is  that it will be
more difficult for them to sell their shares.

Our preference shares could preven t or delay a takeover, page 13
11. Please revise the subheading to clarify that you ha ve not issued any preferred shares to date.

Selling Security Holders, page 13
12. Please include the selling share holder information required by Item 507 of Regulation S-B.
Provide a detailed introductory description of  the transaction by whic h each of the selling
security holders in the table acquired th eir shares.  We note your disclosure under
Transactions Within Last Five  Years regarding unregistered  stock issuances for various
consulting services.
13. Please disclose the natural persons who exercise  sole or shared voti ng and/or investment
power over each of the selling sh areholder entities in the table.  For those entities where you
identify the owner or owners, please state further whether th e owner(s) exercises sole or
shared voting and/or investment power of th e entity listed.  See inte rpretation 4S of the
Regulation S-K portion of the March 1999 supplement to our publicly available telephone
interpretation manual, as we ll as interpretation I.60 of the July 1997 version of our
telephone interpretation manual.

Directors, Executive Officers, Promoters and Control Persons, page 17
14. Please consider relocating the Article III bylaw information that begins this section to the
end of this section.  Note that Item 401 of Regulation S-B requires that you identify the
directors and executive offi cers, among other things, and it would be appropriate to
prominently place the required information a nd provide supplemental information as
necessary.
15. Please tell us who is serving in the role of  chief financial officer  and principal accounting
officer.  We note that the disc losure provided for Ms. Lucas re fers to her experience as a
systems engineer and business entrepreneur.

Joseph P. Coschera
Information Systems Associates, Inc.
June 4, 2007
Page 4

Transactions within the La st Five Years, page 20
16. It appears that you have atte mpted to respond to Item 15, Or ganization within Last Five
Years, before it was amended.  Please revise th e disclosure to respond to the amended Item
15, Certain Relationships and Tr ansactions and Corporate Gove rnance, and to provide the
information required by Item 407(a) of Regul ation S-B.  Please note that Item 404 of
Regulation S-B has also been modified.

Description of Business, page 23
17. We note your disclosure on page 23 and in the summary section that you “plan to continue
to operate as a computer software developer. ”  Please clarify whether you consider your
business to be in the development stage or ot herwise explain the meaning of this phrase.
Further, clarify whether you provide services  through your “insurance sales business,” as
indicated in Note A to the financial Statements, and to what extent you “develop and deliver
comprehensive asset management systems for … real estate … assets” and “real estate
portfolio management.”  See the MD&A discussion on page 29.
18. Please revise the business sect ion to more clearly explain the products and services you
provide.  Clarify whether each of the products yo u list, including Vista, Obtain 24/7, Vision
FM, the Facilities Manager, AutoCAD and RackWise are products developed by you or by third parties.  Where the products are obtained from third parties, discuss the nature of the business relationship with the third party and clearly describe the extent of Information
Systems Associates’ involvement in marketing and servicing any such products and discuss
any revenue sharing agreements.  Then for each  product listed, revise to  better explain what
each product does.  For instance, you state on page 25 that Rackwise services and products “deliver key features to simplify and redu ce the time consumed [sic] designing, modeling
and operating the physical infrastructure of your  datacenter.”  It is not clear from this
statement what Rackwise does.  In addition the bulleted list that follows contains industry
jargon that is not self-explanatory, such as “Auto-Build Visual Documentation From
Imported Bill of Materials” and “General Deta iled Datacenter and Rack Visualizations.”
Finally, clarify whether “On Site  Physical Inventory” is a solution you currently offer.  The
business description should be revised so th at it may be easily understood by someone not
already familiar with you r business and industry.
19. Please briefly define “SLA penalties” and “SANS.”  See pages 23-24.
20. Please provide disclosure regarding the number of total employees and the number of full-
time employees.  See Item 101(b)(12) of Regul ation S-B. In this regard, we note your
disclosure on page 18 that you have no significant employees other than your president and
vice-president.
21. Given that you list only one partner, pl ease consider whether the table on page 26
describing the partner and the “service or offeri ng” is useful.  Further, clarify what the

Joseph P. Coschera
Information Systems Associates, Inc.
June 4, 2007
Page 5

technology infrastructure solutions are that  Forsythe Solutions Group provides and how
they complement the products and services you offer.

Sales and Marketing, page 27
22. You state that you market your se rvices primarily through referrals from your partners.  We
note your disclosure on page 26 identifying only one partner.  (See comment 21 above.)
Clarify whether you have more than one part ner and, if so, describe them.  If you are
referring to different categorie s of partners, please explain.

Technology Platform, page 27
23. Please clarify which partner you are referring to  in your statement that “Our partner’s
technology platform are [sic] based on Microsoft core  applications . . . .”   If you intended to
refer to several partners, please revise the disclosure to clar ify this and to describe the
partners to whom you are referring.

Research and Development, page 28
24. Please explain what the focus of your research  and development efforts was for the year
ended December 31, 2006 as most of your disclo sure appears to relate to research and
development that you expect to undertake sometime in the future.

Competition, page 28
25. Please include a discussion of th e principal competitive factor s in your marketplace.  In
addition, provide your assessment of your competitiv e position with respect to each of these
factors and your assessment of your position re lative to your principal competitors with
respect to each of the principal competitiv e factors.  Tell us how you compare to your
competitors in quantitative or qualitative terms and consider appropriate disclosure in this
respect.  See Item 101(b)(4) of Regulation S-B.

Reports to Security Holders, page 28
26. Please note that the Commission’s offices ha ve changed.  We are now located at 100 F
Street NE, Washington, D.C.  20549.

Management’s Discussion and Analysis, page 29
27. Please ensure that your description of your co mpany and business are consistent with your
descriptions elsewhere in the document, partic ularly the summary and business sections.  It
is unclear, for instance, why the “On Site Phys ical Inventory” soluti on is not discussed in
detail in the business secti on if it is the solution around which your business is formed.

Joseph P. Coschera
Information Systems Associates, Inc.
June 4, 2007
Page 6

28. Explain your reference to the “first full year” with respect to potenti al revenue from your
Data Collection services.  If this service has not been offered in prior years and is
considered a new product offering, this should be made clear in th e business section and
wherever discussed in the prospectus.  Furthe r, tell us the basis fo r projecting income of
$500,000 from this revenue source.  Do you have  contracts, arrangements or agreements
that you believe will generate income at that level?  If not, what is the basis for this
projection beyond discussions with prospective clients?  To the ex tent you provide a
projection or similar statement concerning futu re performance, you must provide sufficient
support for your claim.
29. Please expand to discuss the natu re of your joint venture with Visual Network Design, Inc.
We note that you indicate elsewhere in the prospectus that you are a certified Value Added
Reseller and application integrator for VNDI.  Clarify whether your company is identified on
services quotations submitted by VNDI along with other VARs of whether your business
relationship with VNDI in this regard is exclusive.
30. Please provide support for your statement that with regard to “the relative pricing and
functionality of your product and service offe rings as compared with those of [y]our
competitors,” you consider your service offerings to be competitive.  See page 30.
31. Please explain your statement on page 30 that the 1.4 million shares issued in connection
with general management consulting and advisory  services were valued based on the market
price on the date of the stock gr ant or other measures given yo ur disclosure that there has
been no market for your shares to date.

Liquidity and Capital Resources, page 32
32. Please provide a brief outline of the material terms of the line of credit with First Citizens
Bank and indicate the amount outstandi ng, if any, under the credit line.

Executive Compensation, page 36
33. Please note that narrative disclosure to th e summary compensation table is required where
necessary to an understanding of  the information disclosed in  the table. We note that
bonuses were issued to both of the named execu tive officers. Please discuss the basis for the
bonus issuances and identify the person(s) responsible for authorizing the bonuses. See Item 402(c) of Regulation S-B.

Part II

Undertakings
34. The undertakings set forth in Item 512 of Regulation S-B have been recently revised.  Please update to include the currently required undertakings outlined in paragraph 512(g)(1)

Joseph P. Coschera
Information Systems Associates, Inc.
June 4, 2007
Page 7

or (g)(2) of Regulation S-B, as  appropriate.  Note that paragr aph 512(g)(i) relates to issuers
relying on Rule 430B and 512(g)(ii) rela