July 19, 2007

Mr. Daniel L Gordon, Branch Chief
United States Securities and Exchange Commission
Division of Corporate Finance
Washington, DC 20549

     Re:  Trey Resources Inc.
          Form 10KSB for the year ended December 31, 2006
          Filed 4/9/07
          File No. 000-50302

Dear Mr. Gordon;

We are in receipt of your comment letter dated May 29, 2007 in conjunction with
your review of Trey Resources Inc.'s consolidated financial statements and
related Management's Discussion and Analysis disclosures in its annual report on
Form 10-KSB. We have carefully considered your comments and respectfully offer
the following responses.

COMMENT

Revenue Recognition, page 15

Please elaborate upon your software revenue recognition policy in future filings
pursuant to paragraph 12 of APB 22. In supplemental response, please provide us
with the disclosure you will include in future filings and clarify how you
determined that policy complied with SAB 101. Specifically address how you
account for the resale of software when additional services are provided as
contemplated on page 5 of the Description of Business section and whether you
account for the re-sale of software on a gross or net basis.

RESPONSE

The Company accounts for the resale of software on a gross basis and does not
recognize revenue on the sale of the software until the cash has been received
from the customer and the product has been delivered. (It is the Company's
policy that payments for software sales are due in advance of ordering from the
software supplier). For those sales that involve additional services, the
Company separates the software component and the professional services component
into two distinct parts for purposes of determining revenue recognition. In that
situation where both components are present, software sales revenue is
recognized when the cash is received and the product is delivered, and
professional service revenue is recognized as the service time is incurred.
(Payment for professional services is due 50% in advance and is treated as a
customer deposit liability until such time as it is earned by virtue of actual
service time being incurred).



The Company acknowledges that it is responsible for the adequacy and accuracy of
the disclosures in its filings; staff comments or changes to disclosure in
response to staff comments do not foreclose the Commission from taking any
action with respect to the filings, and the Company 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.

It is anticipated that future filings will contain the following disclosure
which complies with SAB 101:

REVENUE RECOGNITION

"Revenue is recognized when persuasive evidence of an agreement exists, delivery
has occurred, the amount is fixed or determinable, and cash is received.

The Company recognizes revenues from consulting and support services as the
services are performed.

The assessment of collectibility is critical in determining whether revenue
should be recognized. As part of the revenue recognition process, we determine
whether trade receivables are reasonably assured of collection based on various
factors. Revenue and related costs are deferred if we are uncertain as to
whether the receivable can be collected. Revenue is deferred but costs are
recognized when we determine that the collection of the receivable is unlikely."

If you have any questions please don't hesitate to contact the undersigned at
(973) 958-9555.

Sincerely,


Mark Meller, President
Trey Resources Inc.