Mail Stop 4561

      April 10, 2006

Mr. Robert C. Harvey
President
Oakridge Holdings, Inc.
4810 120th Street West
Apple Valley, MN  55124


      Re:	Oakridge Holdings, Inc.
		Form 10-KSB for the Year Ended June 30, 2005
		Filed September 27, 2005
		File No. 0-01937

Dear Mr. Harvey:

      We have reviewed your response letter dated February 22,
2006
and have the following additional comments.  As previously stated,
these comments require amendment to the referenced filings
previously
filed with the Commission.  Where indicated, we think you should
revise your document 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 one of our comments, we ask you
to
provide us with information so we may better understand your
disclosure.  After reviewing this information, we may 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
filings.
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.

Form 10-KSB for the year ended June 30, 2005

Report of Independent Registered Accounting Firm

1. We note your response to comment 1.  Please file an amended
Form
10-KSB to revise the report in the 6/30/2005 filing to refer to
the
standards of the Public Company Accounting Oversight Board.


Consolidated Balance Sheets

2. We note your response to comment 2.  Please tell us what
consideration you gave to performing an impairment analysis on the
Apple Valley land in accordance with the guidance of paragraph 8f
of
SFAS 144.

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please file your response on EDGAR.  You may
wish
to provide us with marked copies of the amendment to expedite our
review.  Please furnish a cover letter with your amendment that
keys
your responses to our comments and provides any requested
information.  Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 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 filings or
in
response to our comments on your filings.

      You may contact Matthew Maulbeck, Staff Accountant, at (202)
551-3466 or the undersigned at (202) 551-3403 if you have
questions.



								Sincerely,



      Steven Jacobs
      Accounting Branch Chief

Mr. Robert C. Harvey
Oakridge Holdings, Inc.
April 10, 2006
Page 1