Innovative Software Technologies, Inc.

911 Ranch Road 620 North

Austin, Texas 78734

July 20, 2007

VIA FACSIMILE AND EDGAR

Michael McTiernan, Staff Attorney

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Innovative Software Technologies, Inc.

Registration Statement on Form SB-2

File No. 333-140596

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), Innovative Software Technologies, Inc. (the “Company”) respectfully requests that the effective date of the registration statement referred to above be accelerated so that it will become effective at 4:00 p.m., Eastern Time, on Monday, July 23, 2007, or as soon thereafter as possible.

We hereby acknowledge the following:

·    that should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·    the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

INNOVATIVE SOFTWARE TECHNOLOGIES, INC.

By: /s/ Philip Ellett                                                               

Name: Philip Ellett

Title: Chief Executive Officer