Mail Stop 4561 January 19, 2006 Mr. Christopher J. Floyd Chief Financial Officer Innovative Software Technologies, Inc. 100 North Tampa Street Suite 2410 Tampa, FL 33602 Re:	Innovative Software Technologies Inc. 		Form 10-KSB for the Year Ended December 31, 2004 		Filed May 5, 2005 		File No. 0-27465 Dear Mr. Floyd: We have completed our review of the forms listed above and related filings and have no further comments at this time. 								Sincerely, Steven Jacobs Accounting Branch Chief ?? ?? ?? ??