Mail Stop 4561
      March 15, 2006

Mr. Wayne I. Danson
President
Advanced Communications Technologies, Inc.
420 Lexington Avenue
New York, NY 10170

	Re:	Advanced Communications Technologies, Inc.
		Form 10-K for the Fiscal Year Ended June 30, 2005
		Form 10-Q for the Three Months Ended September 30, 2005
		File No. 0-30486

Dear Mr. Danson:

      We have reviewed your response letter dated February 23,
2006
and have the following additional comment.  In our comment, we ask
you to provide us with additional information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not raise additional comments.

       Please understand that the purpose of our review 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 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.

Note 9 - Notes and Loan Payable, page F-14

1. We note your response to our previous comment four.  Please
address the following comments:

* Tell us if the deferred finance fees were costs incurred to
enter
into the loan transaction (e.g., lawyer fees, accountant fees,
etc.)
or a fee charged by Cornell Capital Partners LP to borrow the
money
over the life of the loan.
* Explain to us the basis for your assertion to the effect that
the
promissory note was issued in connection with the equity line of
credit; tell us the expiration date of the equity line of credit.
* We note that the loan was originally payable in six months,
would
become interest-bearing at the lower of 24% or the highest rate
permitted by law if not paid when due, and was subsequently
modified.
Please explain to us how you considered EITF 96-19 in determining
how
to account for these modifications.

      Please respond to the comments included in this letter
within
ten business days.  If you have any questions, you may contact
Thomas
Flinn, Staff Accountant, at (202) 551-3469 or the undersigned at
(202) 551-3414 if you have questions.
      			Sincerely,


      Jorge Bonilla
      Senior Staff Accountant



Mr. Wayne I. Danson
Advanced Communications Technologies, Inc.
March 15, 2006
Page 1