SecProbe.io

Mail Stop 4561        August 8, 2007

Joseph P. Coschera Chief Executive Officer Information Systems Associates, Inc. 2120 SW Danforth Circle  Palm City FL 34990
 Re:  Information Systems Associates, Inc.
  Amendment No. 1 to Form SB-2   Filed on July 10, 2007   File No. 333-142429

Dear Mr. Coschera:        We have reviewed your responses to our prior letters and your amended filing
on Form SB-2 and have the following comment s.  Please note that the comments issued
in this letter relate to pr ior accounting comments issued in  our letter dated May 24, 2007
and comments issued in our lette r dated June 7, 2007, as specified.

UGeneral

1. Please refer to prior comments 2, 18 and 27 of our letter dated June 7, 2007.  We
note your revisions to the summary and business sections; ho wever, it appears
that these sections continue  to require significant revision.  The disclosure as
currently drafted remains unclear as to your current business focus and offerings
and should be revised to address clearl y and concisely the following matters:

• Where you initially describe your busi ness, please clarify that ISA is a
value added reseller and its product and service offerings are limited to
those produced by third parties; further,  please identify the third parties.

• You make several claims regarding the focus of your business, which do
not appear to be consistent.  Please  review the following statements and
revise as necessary to ensure th at you have provided a consistent
description of your business fo cus throughout the document.

Joseph P. Coschera
Information Systems Associates, Inc. August 8, 2007
Page 2

o Page 5:  You are “currently engage d and plan to continue in the
development and sale of financial and asset management software business”;
o Page 25:  Your primary focus has been to offer for sale “software
products and services that allow companies to track and manage
assets, primarily in the realm of corp orate real estate and corporate IT
network infrastructure”;
o Page 34:  “Information System Asso ciates major activity is around our
information technology Asset Invent ory solution ‘On Site Physical
Inventory’`”;
o Page 62:  “The Company provides services and software system
design for the planning and impl ementation of Computer Aided
Facilities Management (CAFM) based asset management tools. The company also provides services thro ugh its insurance sales business.”

• Include a discussion of your insurance sales business as described in Note
A to the financial statements, incl uding a discussion of what portion of
your revenues is derived from this business.

• Of the four VAR relatio nships, clarify the extent to which you are
substantially dependent on one or more  these relationships.  To the extent
you are substantially dependent on any of the partners, any contractual
arrangements you have with them s hould be filed as exhibits to the
registration statement pursuant to Item  601(b)(10) of Regulation S-B.

• It appears from your responses that you are not currently marketing and
distributing your proprietary internal  data collection solution “On Site
Physical Inventory.”  To the extent  this software product has not been
brought to market, please reconcile the disclosures that suggest you are
currently marketing and distributing this  product.  In this regard, we note
your references on pages 30, 32, 34, which may suggest that you are currently marketing and distributing OSPI.

• Given that all of the products and services you currently offer are third-
party products, please revise the su bheading on page 30 titled “Third Party
Offerings” to distinguish it from your core third-party offerings.  Identify
the number of such additional third-party offerings you provide and disclose the percentage of your reve nues generated by sales or referrals
relating to these additional third-party offerings.  To the extent such sales are not material to the co mpany, please clarify this.

2. Please revise to eliminate the repetitive paragraphs and phrases in the business
section.  See for example the paragraph on page 26 that reads in part “We began

Joseph P. Coschera
Information Systems Associates, Inc. August 8, 2007
Page 3

using Aperture’s Network Management tools,” and your customer list also on
page 26, both of which are repetitive of in formation already provided on page 25.
 3. Please eliminate the footnotes to the prospect us (other than footnotes to the selling
shareholder table or other tables) as they  are not viewable on EDGAR.  Consider
instead incorporating the footnoted inform ation into the text of the prospectus.

USummary, page 5
 4. Please refer to prior comment 4 of our le tter dated June 7, 2007.  Please advise as
to what portion of your revenues is deri ved from Comcast Communications as it
appears that this information was not provi ded with your response.  To the extent
that Comcast is not a material customer, we believe that it would be inappropriate
to identify it by name in the summary section.

5. We reissue prior comment 5 of our letter dated June, 2007, in part.  It appears that
the Value Added Reseller agreement with Aperture should be filed as an exhibit
to the registration statemen t since your business is substantially dependent upon
this agreement.  Please advise or revise.

6. Please refer to prior comment 6 of our letter dated June 7, 2007.  Please specify
the vendors and/or manufacturers of the fac ilities solutions you offer and disclose
what portion of your revenues is derived from  such sales.  To the extent such sales
are not material to the co mpany, please clarify this.

UFinancial Summary Information, page 7

7. Please revise to correct the “Net income  (loss)” dollar amount for the year ended
December 31, 2006.  In this regard, the amounts on page 8 and the first risk factor on page 9 differ from your statements of operations on page 59.

USelling Security Holders, page 14

8. Please refer to prior comment 12 of ou r letter dated June 7, 2007.  We note the
revised disclosure concerning the se lling shareholders who provided you
consulting services in exchange for shar es of your common stock.  Please advise
as to how the remaining shareholders rece ived their shares.  This disclosure may
be provided using footnot es as appropriate.

9. Please refer to prior comment 13 of our letter dated June 7, 2007.  We note that
you have identified only in some cases whether the owner(s) of the selling
shareholder entities had sole or shared voting and/or investment power over the
entities.  Please disclose the natural pe rsons who exercise sole or shared voting
and/or investement power of each of the remaining selling shareholder entities,
i.e., Arabelle Financial limited, Aviati on Interior, Blue Ma rlin, Inc., Citation

Joseph P. Coschera
Information Systems Associates, Inc. August 8, 2007
Page 4

Services, Division Limited, International Engineering Services Limited, Simons
Muirhead and Burton Solicitors.

10. Please tell us whether any of the selling shareholders are broker-dealers or broker-
dealer affiliates.  If any of these entities  are registered broker-dealers, they must
be named as underwriters.  If any are aff iliates of broker-dealers, please include a
representation in the docume nt, if true, that they pur chased the shares in the
ordinary course of business and at the tim e of the purchase of the securities to be
resold, they had no agreements or understand ings, directly or indirectly, with any
person to distribute  the securities.

UDirectors, Executive Officers, Promoters and Control Persons, page 19
 11. Please refer to prior comment 15 of our letter dated June 7, 2007.  Please describe
Mr. Coschera’s experience with financia l accounting and prepar ation of periodic
and annual reports under the Exchange Act, which you will be obligated to file in
the event that this registration statement is declared effective.  In view of his roles
as principal executive officer, chief fi nancial officer and principal accounting
officer, a discussion of his competence/experi ence in this area is an appropriate
subject for disclosure.   Furthermore, c onsideration should be given as to whether
risk factor disclosure is appropriate.

UCertain Relationships and Transactions  and Corporate Governance, page 22

12. Please refer to prior comment 16 of our letter dated June 7, 2007.  Please disclose
the standard used in your determinati on that Mr. Coschera and Ms. Lucas are
“independent directors.”  See Item 407(a) of Regulation S-B.  Explain what is
meant by your statement that they “inde pendently approved” the transactions
listed in this section.
 13. For each of the transactions listed, please disclose the basis on which the person is
a related person and in transactions wh ere shares were issued for services
rendered, the nature of the services.  See Item 404(a)(1) and (6) of Regulation
S-B.

UDescription of Business, page 25
 14. Please refer to prior comment 20 of our letter dated June 7, 2007.  Please disclose
whether the two employees are full- time or part-time employees.
 15. Please refer to prior comment 21 of our le tter dated June 7, 2007.  Consistent with
our comment above, please clarify whethe r OSPI is currently being offered to
Forsythe customers as indicated in your  response or whether OSPI is in the
product development stage only.

Joseph P. Coschera
Information Systems Associates, Inc. August 8, 2007
Page 5

UCustomers, page 31

16. We note that revenues generated by Northrop Grumman Electronic Systems
represented 15.9% and 22.5% of your re venues for the fiscal year ended
December 31, 2006 and the quarter e nded March 31, 2007.  Please file any
agreements with Northrop Grumman as exhi bits to the registration statement or
advise as to why this is not required under Item 601(b)(10)  of Regulation S-B.

UCompetition, page 33
 17. Please refer to prior comment 25 of our letter dated June 7, 2007.  Please clarify
whether data collection services is properl y characterized as one of the two areas
of focus of your business.  If so, please revise throughout the prospectus to clarify
this.
 18. If you retain the disclosure regarding data collection se rvices in your competition
discussion, please revise to identify the principal bases on which you compete for
business and describe your competitive position in the industry.  The disclosure appears to be focused on describing the da ta collection services process and its
advantages rather than on the competitive business conditions.

UManagement’s Discussion and Analysis, page 34

19. Please refer to prior comment 28 of our letter dated June 7, 2007.  We are unable
to concur with your view that you have  a reasonable basis for projecting annual
gross revenues of $500,000 from data collec tion services alone by the end of the
first full year of implementation.  Your re venues for the past two years have not
exceeded $365,000 per year and you have no current contractual arrangements in place whereby you could project such a reve nue stream.  Your response indicates
that you presently are relying on severa l bids, none of which may come to
fruition, and unproven interest generated fr om your partner re lationships.  Please
revise.

20. Please refer to prior comment 29 of our le tter dated June 7, 2007.  It appears from
your response that you do not currently have  an exclusive relationship with Visual
Network Design, Inc.  In this regard, te ll us whether ISA is identified as the
exclusive Value Added Reseller for VNDI in any geographic location.  To the
extent there is no exclusive relationshi p, and absent the existence of a joint-
venture agreement, it appears inappropriate to describe th is relationship as a “joint
venture.”  Please revise accordingly.

Joseph P. Coschera
Information Systems Associates, Inc. August 8, 2007
Page 6

UFinancial Statements
21. Please revise your next am endment to include updated financial
statements and related consents.  S ee Item 310(g) of Regulation S-B.

UNote A – Summary of Significant Accounting Policies

URevenue Recognition, page 62

22. Your response to prior comment num ber 6 of our letter dated May 24, 2007
indicates that you resell and install softwa re.  It is unclear to us how you have
concluded that you are not subject to SOP 97-2 considering that your response
indicates that you sell soft ware.  Please explain your  basis for concluding that
SOP 97-2 does not apply to you and explai n how you considered paragraph 2 of
the SOP.

23. Your response to prior comment num ber 7 of our letter dated May 24, 2007
indicates that you do not have multiple -element arrangements, however your
disclosures on page 30 indicate that in connection with your software offerings
you also provide various services incl uding consulting, training, and maintenance
and support. These appear to be multiple -element arrangements.  As previously
requested, please revise your disclosure to  identify all elements included in each
significant type of sales transaction and explain how you determine whether
elements should be considered separate  units of accounting or combined with
other elements.  Clearly explain how you allocate revenue to each accounting unit
and describe, for each unit, how you meet the relevant revenue recognition criteria that are referred to in your policy.  Your  disclosures should be robust and specific
to the applicable guidance such as SAB 104, EITF 00-21, and SOP 97-2.

UShare-Based Payments, page 64

24. Please tell us why it was a ppropriate to consistently value shares issued for
services at the low end of the range that you have sold your stock.  In addition, tell us why you have not included any in formation regarding these transactions
within your audited financial statements.
 25. We note that your disclosures here and on pa ge 52 continue to refer to the use of
the “quote at the close of market trad ing,” however your response to prior
comment number 9 from our letter date d May 24, 2007 indicates that you do not
trade on a public market.  Please re vise your disclosures accordingly.

Joseph P. Coschera
Information Systems Associates, Inc. August 8, 2007
Page 7

UPart II

UUndertakings

26. Please refer to prior comment 34 of our letter dated June 7, 2007.  We note that
you have provided only part of the unde rtaking required by Item 512(g)(1) of
Regulation S-B.  Moreover, in selecti ng 512(g)(1), you have relied on Rule 430B,
which does not appear to apply to you.  Please revise to provide the applicable
undertaking in its entirety.

USignatures

27. Please update the signature page with each amendment so that it reflects the date
of or a date close to the date of filing.

You may contact Christine Davis at 202-551-3408 or Ma rk Kronforst, Accounting
Branch Chief, at 202-551-3451 if you have questions regarding comments on the financial statements and related matters.  Pl ease address all other comments to Maryse
Mills-Apenteng at 202-551-3457 or, in her ab sence, to the unde rsigned at 202-551-3735.
         S i n c e r e l y ,             B a r b a r a  C .  J a c o b s          A s s i s t a n t  D i r e c t o r
cc:
UVia facsimile:  772-286-3031
 Information Systems Associates, Inc.