November 14, 2009


U.S. Securities and Exchange Commission	                   BY EDGAR
100 F Street, N.E.
Washington, DC  20549
Attention:	Mr. Kevin Woody
		Accounting Branch Chief

Re: Oakridge Holdings, Inc.
    Amendment No. 1 to Form 10-K for Fiscal Year Ended
    June 30, 2008
    Filed September 29, 2009
    Form 10-KSB for Fiscal Year Ended
    June 30, 2008
    Filed September 29, 2008
    Form 10-Q for the Quarterly Period Ended
    September 30, 2008
    Filed November 12, 2008
    Form 10-Q for the Quarterly Period Ended
    December 31, 2008
    Filed February 17, 2009
    Definitive Proxy Statement
    Filed October 27, 2008
    File No. 000-01937



Ladies and Gentlemen:

On behalf of Oakridge Holdings, Inc. ("Oakridge" or the "Company"), I am pleased
to submit this response to the comments of the Staff on the above-referenced
filings, as set forth in Mr. Woody's letter to me dated November 10, 2009. For
convenience, the Staff's numbered comments are set forth below, followed by
Oakridge's responses.

Oakridge hereby represents that (i) it is responsible for the adequacy and
accuracy of the disclosure in the filings, (ii) Staff comments or changes to
disclosure in response to Staff comments in the filings reviewed by the Staff
do not foreclose the Securities and Exchange Commission from taking any action
with respect to the filings and (iii) Oakridge may not assert Staff comments as
a defense in any proceeding initiated by the Securities and Exchange Commission
or any person under the federal securities laws of the United States.

Amendment No. 1 to Form 10-K for Fiscal Year Ended June 30, 2008

1.  Comment:  We note your reference to the Private Securities Litigation Reform
    Act of 1995. Please note that the safe harbors for forward-looking
    statements provided by the PSLRA are not available to penny stock issuers.
    In future filings, please either remove the reference to the PSLRA or
    explain to us why you believe you are eligible to take advantage of the safe
    harbors for forward-looking statements.

    Response:  The Company will not reference the PSLRA in future filings.

2.  Comment:  In your response to comment 10 in our letter dated March 3, 2009,
    you indicated that Robert Harvey is your chief executive officer, chief
    financial officer and principal accounting officer. In future filings,
    please also include the title of "principal accounting officer" in Mr.
    Harvey's signature block.

    Response:  The Company will add "principal accounting officer" to Mr.
    Harvey's signature block in future filings.

If we can facilitate the Staff's review of this letter, or if the Staff has any
questions on any of the information set forth herein, please telephone me at
(651) 454-5112.  My fax number is (651) 454-5143.


Sincerely,

/s/ Robert C. Harvey

Robert C. Harvey
President and Chief Executive Officer