October 2, 2006


Stephen Krikorian, Account Branch Chief
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549-3628

RE:     PAR Technology Corporation
        Form 10-Q for Fiscal Quarter Ended June 30, 2006
        File No. 001-09720

Dear Mr. Krikorian:

     This letter reflects PAR Technology Corporation's responses to the comments
contained  in the  letter  from the  Commission's  Staff (the  "Staff")  to John
Sammon,  Jr.  dated  September  5, 2006.  The  response set forth below has been
organized in the same manner in which the Staff's  comment was  presented in the
Staff's letter.

Form 10-Q for the Quarterly Period Ended June 30, 2006

Item 4.  Controls and Procedures

COMMENT 1.     We note your  disclosure  that you carried out an  evaluation  of
               internal  control over financial  reporting,  in addition to your
               evaluation of disclosure  controls and procedures,  as of the end
               of the period  covered by the report.  Tell us the nature of this
               evaluation of internal control over financial  reporting.  If you
               have made more  frequent  assessments  of internal  controls over
               financial reporting than the annual requirement of Rule 13a-15(c)
               of the  Exchange Act of 1934,  revise to include all  disclosures
               required by Item 308 of Regulation S-K.

 RESPONSE 1.   We  acknowledge  the  existence  in our Form 10-Q for the  period
               ended June 30,  2006,  of an  inadvertent  statement  that we had
               "carried out an  evaluation  of the  effectiveness  of disclosure
               controls and procedures  ... and internal  control over financial
               reporting  ...  ."  An  evaluation  of  disclosure  controls  and
               procedures was, in fact, conducted; however we have not conducted
               a more  frequent  assessment of internal  control over  financial
               reporting since our evaluation conducted as of December 31, 2005.
               Indeed,  all other aspects of the disclosure  refer solely to the
               evaluation  of  disclosure  controls  and  procedures.  In future
               quarterly  filings,  the Company  will modify its  disclosure  to
               include only the evaluation of disclosure controls and procedures
               as required under S-K Item 308, as applicable.

     Please  contact  me  at  (315)  738-0600,  should  you  require  additional
information or have questions regarding this letter.

                                          Very truly yours,

                                          PAR TECHNOLOGY CORPORATION


                                          By: /s/Ronald J. Casciano
                                          -------------------------
                                              Ronald J. Casciano
                                              Vice President,
                                              Chief Financial Officer
                                              and Treasurer