Innovative Software Technologies, Inc.
                                           100 North Tampa Street, Suite 2410
                                                  Tampa, Florida 33602
                                                Phone: (813) 387 - 3310
                                                 Fax: (813) 387 - 3311
================================================================================

December 12, 2005


Steven Jacobs
Matthew Maulbeck
Division of Corporate Finance
Securities and Exchange Commission
Washington, D.C. 20549
Mail Stop 4561

Re:      Innovative Software Technologies, Inc.
         Form 10-QSB for the Quarter Ended June 30, 2005
         Filed September 1, 2005
         File No. 0-27465


Gentlemen:


This letter is in response to your comments to the company of November 3, 2005.

Form 10-QSB for the Quarter Ended June 30, 2005
Consolidated Statement of Operations, page 4


1. We note your  disclosures  on page  F-19 of Form  10-KSB  that you have,  "no
continuing  involvement  with EPMG or Triad,"  and that in the future  financial
statements,  "will  be  restated  to  reflect  EPMG and  Triad  Media,  Inc.  as
discontinued  operations."  In light of these  disclosures,  please  tell us why
these operations,  including the goodwill impairment, have not been reflected as
discontinued  operations in the June 30, 2005 and 2004 statements of operations.
Reference is made to paragraphs 41 - 44of SFAS 144.


Our  conclusion to not report the  operations  of EPMG and Triad Media,  Inc. as
discontinued  operations in the June 30, 2005 and 2004  statements of operations
is based on our  understanding  of the reporting  required by the SEC as well as
FAS 144 when a company has no continuing operations.  We understand that the SEC
would  not  expect  to see  an  Issuer  account  for  its  only  operation  as a
discontinued operation, in the absence of continuing operations. We believe that
position is consistent with the language in paragraphs 41-44 of SFAS 144.


                                         Innovative Software Technologies, Inc.
                                           100 North Tampa Street, Suite 2410
                                                  Tampa, Florida 33602
                                                Phone: (813) 387 - 3310
                                                 Fax: (813) 387 - 3311
================================================================================

We reasonably  expected that we would have continuing  operations at the time of
the filing of our Form 10-KSB  because we had executed  purchase  agreements for
other  businesses.  It was our intention to report the acquired  businesses as a
predecessor in order to show a history of the ongoing operations.  However, with
the rescission of the acquisition of Data Tech (reference our filing on Form 8-K
of June 28, 2005) the Company has no continuing operations and therefore decided
that showing all historical operations as discontinued would not be appropriate.

We have  disclosed in our press  release and related  filing on Form 8-K of July
18, 2005 that we have no continuing operations. In that filing we stated:

            "Currently  Innovative Software  Technologies,  Inc. has no business
            operations. Our strategy is to engage in a business combination with
            a company that has operations.  Such a transaction  could include an
            acquisition  of an  operating  business  or a  merger  with  another
            entity. However, there can be no assurances that the company will be
            able to succeed in  identifying  a candidate  for such a transaction
            or, if such a candidate is identified,  that such a transaction  can
            be successfully negotiated."

Should management be successful in identifying,  negotiating and closing another
acquisition,  we would expect to use predecessor accounting going forward, where
we would  report the  operations  of the  acquired  company to which our Company
would have succeeded to. We note that if purchase  accounting is appropriate for
such transaction,  it would be applied.  However,  if the transaction  should be
accounted for as a reverse merger,  we will report the historical  operations of
the predecessor.

Innovative Software  Technologies,  Inc. acknowledges that it is responsible for
the adequacy and accuracy of the disclosure in the filings,  that staff comments
or changes to  disclosure  in response to staff  comments do not  foreclose  the
Commission  from taking and action with respect to the filings,  and that it 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.

Sincerely,


/s/ Christopher J. Floyd
- ------------------------
Christopher J. Floyd
Chief Financial Officer