Mail Stop 0511					September 27, 2004



Timothy P. Beck, Chairman
IntelliServices, Inc.
5620 Paseo del Norte
Suite 127-501
Carlsbad, CA  92008

Re:  	IntelliService, Inc.
        	Registration Statement on Form 10-SB
        	File No.  0-50948
        	Filed September 21, 2004

Dear Mr. Beck:

	    A preliminary review of your registration statement has been
done and we have the following comments.

Part II

Item 4.  Recent Sales of Unregistered Securities, Page 19

1. We direct your attention to the letter of January 21, 2000 to Mr.
Ken Worm, Assistant Director of the OTC Compliance Unit at NASD.  This
letter indicates our view that the securities issued by a blank check
company cannot be resold under Rule 144 but must be registered under
the Securities Act of 1933.   Amend the registration statement
throughout to make the appropriate additions to conform to this
comment.

No further review of your filing will be made at this time.  You are
requested to file an amendment on Form 10SB12G/A to include the
necessary information within fifteen business days, or inform the
staff prior to that time when the amendment will be made.






Other

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  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 in the filings reviewed by the staff 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.

*******

	Please be advised that your registration statement will
automatically become effective 60 days after filing.  Upon
effectiveness, you will become subject to the reporting requirements
of the Securities Exchange Act of 1934, even if we have not cleared
your comments.  Note that the NASD Bulletin Board will not accept your
listing until we have cleared all comments.  In the event that it
appears that you will not be able to respond by the 60th day, you may
wish to consider withdrawing your registration statement and refilling
when you have prepared a response to our comments.  In addition,
should the filing become effective in its present form the Division
would be required to consider what recommendation, if any, it should
make to the Commission.





	Any questions on the above matters may be directed to the
undersigned at (202) 942-2999 or Goldie B. Walker at (202) 942-1986.

						Sincerely,



						John D. Reynolds, Assistant Director
					            Office of Emerging Growth
Companies


Timothy P. Beck, Chairman
IntelliServices, Inc.
September 27, 2004
Page 3