December 22, 2009



Katherine Wray
Attorney-Advisor
Division of Corporation Finance
Securities and Exchange Commission
100 F Street NE
Washington, D.C.  20549

Re:      Alanco Technologies, Inc.
         Registration Statement on Form S-3
         Filed on November 23, 2009
         File No. 333-163288

         Form 8-K filed September 23, 2009, as amended December 7, 2009
         File No. 000-09347

Dear Ms. Wray:

Alanco received your comment letter, dated December 22, 2009, pertaining to a
review by the SEC of our Form S-3 filed on November 23, 2009. In addition to the
Form S-3, the comments referenced our Form 8-K indicated above. We have filed a
marked copy of our amended Form S-3.

Presented below are the SEC comments specified in the December 22, 2009 letter
and, in bold italics, the Company's response or proposal to resolve the
deficiencies noted:

Form S-3
- --------

General
- -------

1.       It is unclear from your  registration  statement  whether you are
         seeking to register  the offering of preferred  stock of the company.
         In this regard, we note, as examples only, the following
         inconsistencies in your filing:

         o The registration fee table in the forepart of your registration
           statement does not list any preferred stock among the classes of
           securities to be registered, but footnotes (1) and (3) to the fee
           table indicate that you are seeking to register shares of your
           preferred stock.

         o Disclosure elsewhere in your filing, for example on your prospectus
           cover page, indicates that the registration statement relates only to
           the offering from time to time of shares of your Class A common
           stock, warrants to purchase Class A common stock, and units
           comprising the foregoing securities. However, disclosure elsewhere,
           for example on page 5 under the heading "The Securities We May Offer"
           and in your description of warrants on page 7 suggests that you are
           seeking to register the offering of (among other securities) warrants
           to purchase preferred stock and units that include preferred stock.

         Please revise your fee table and disclosure throughout the registration
         statement as appropriate to clarify the nature of the securities you
         are seeking to register for the shelf. If you intend to register the
         offering of warrants that are exercisable for preferred stock within
         one year, please be advised that you must register the underlying
         preferred stock at the same time as the warrants.

         Per your comments, we have revised footnotes (1) and (3) to our fee
         table as requested.

         Per your comments, we have revised section "The Securities We May
         Offer" on page 5 as requested.

         Per your comments, we have revised section "Description of Capital
         Stock" on page 7 as requested.


Exhibits
- --------

General
- -------

2.       The legal opinion and auditor's consent have been filed on Edgar as
         part of the body of the registration statement, instead of as separate
         exhibits to the filing. Please file these and any other required
         exhibits as separate exhibits on EDGAR using appropriate header tags.
         For assistance, you may contact the EDGAR Filer Support and Filer
         Technical Support branches at (202)551-8900.

         Per your comments, the legal opinion and auditor's consent have been
         removed from the S3 and filed as separate exhibits.

Exhibit 5.1, Opinion of Law Office of Steven P. Oman, P.C.
- ----------------------------------------------------------

3.       As it appears that you are registering rights attached to shares of
         your Class A common stock, please have counsel file a revised legal
         opinion that addresses whether the rights will be legal binding
         obligations of the registrant under the state law contract governing
         the rights agreement. In addition, further to comment 1 above, if
         shares of preferred stock are being registered as well, the opinion
         should be expanded to address whether such shares will be legally
         issued, fully paid and non-assessable.

         Per your comments, counsel has filed a revised legal opinion as
         requested.

Incorporation by Reference
- --------------------------

4.       Please revise to specifically incorporate by reference all filings
         required by Item 12 of Form S-3. In this regard, we note that it
         appears that you should incorporate by reference the current reports on
         Form 8-K filed by the company on September 11, 2009, September 18, 2009
         (two reports), September 23, 2009 (as amended on December 7, 2009),
         October 29, 2009, and November 24, 2009.

         Per your comments, we have added additional 8-K's to section
         "Information Incorporated by Reference" as requested.

Form 8-K, as amended
- --------------------

5.       The cover page of the amended filing lists the "Date of Report" as
         December 7, 2009. Please note that the date of report should represent
         the date of the earliest event reported in your Form 8-K. Confirm your
         understanding in this regard in your response letter, and prepare
         future current reports accordingly.

         We confirm our understanding that the date of report should represent
         the date of the earliest event reported in our Form 8-K and will
         prepare future current reports accordingly.


If you have any questions, please contact John Carlson directly at
(480) 505-4869.

Sincerely,



Robert R. Kauffman
Chief Executive Officer