Room 4561
						August 5, 2005



Mr. Martin Wade III
Chief Executive Officer
International Microcomputer Software, Inc.
100 Rowland Way
Suite 300
Novato, CA 94945

Re:	International Microcomputer Software, Inc.
	Form 10-KSB for Fiscal Year Ended June 30, 2004
	Filed September 13, 2004
	Form 8-K filed July 7, 2005
	File No. 000-15949


Dear Mr. Wade:

      We have reviewed your response letter dated July 18, 2005
and
have the following additional comments.  We may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or 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 fiscal year ended June 30, 2004

Note 1 - Summary of Significant Accounting Policies

Marketable Securities, page 39

1. Your response to prior comment number 4 indicates that you did
not
have any investments classified as available-for-sale as of June
30,
2004 and 2003. However, you disclose that "we classify all of our
marketable securities as available-for-sale" on page 39 of your
Form
10-KSB.  Please explain this inconsistency to us. In addition,
explain to us how you considered the guidance in paragraph 118 of
SFAS 115 that requires cash flows related to trading securities to
be
classified as operating within your statements of cash flows.

2. Your response to prior comment number 4 also indicates that you
classified the shares of Jupitermedia held in escrow from the sale
of
ArtToday as trading securities.  Please explain to us how these
escrow securities were used with the objective of generating
profits
on short-term differences in price and further explain why you
believe these securities have all of the characteristics of
trading
securities.

Note 2 - Discontinued operations

Sale of Keynomics, page 43

3. We have read your response to prior comment number 6 and note
that
it appears that you did not address whether you have eliminated
the
cash flows related to Keynomics as required under paragraph 42 of
SFAS 144. Please explain to us how you have concluded that the
cash
flows have been eliminated considering the existence of the
license
agreement.

Form 8-K filed July 7, 2005

4. Please explain to us how you considered providing pro forma
financial information reflecting your disposition of Allume in
accordance with Item 9.01(b) of Item 8-K.

	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 submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
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 any amendment and your responses to our comments.

	You may contact Christine Davis, Staff Accountant, at (202)
551-
3408, Mark Kronforst, Senior Staff Accountant at (202) 551-3451 or
me
at (202) 551-3489 if you have questions regarding these comments.

Sincerely,



      Brad Skinner
							Accounting Branch Chief
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Mr. Martin Wade
International Microcomputer Software, Inc.
August 5, 2005
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