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MB                                          777 Main Street- Suite 3100
                                            Fort Worth, Texas 76102
SOFTWARE CORPORATION                        (817) 820-7080   FAX (888) 8746-7566
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November 27, 2007

United States
Securities and Exchange Commission
Washington, DC 20549
Mail Stop 6010

Re: SEC comment letter dated November 26, 2007

Dear Mr. Kuhar:

In  reference  to your letter of November  26, 2007 we  respectively  submit the
following.

Form 10-KSB/A for the Fiscal Year Ended December 31, 2006.
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Report of Independent Registered Public Accounting Firms, Page F-2
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We see that your filing does not include an audit report  covering the statement
of income,  cash flows and  changes in  stockholder's  equity for the year ended
December 31, 2005,  and  therefore  appears to be  unaudited.  Please revise the
filing to present the report from your independent  auditors as required by Item
310(a) or Regulations S-B or tell us why such report is not required.

Response: We have corrected on our December 31, 2006 Form 10-KSB/A.

Item 8A. Controls and Procedures, Page 24
-----------------------------------------

We note your  disclosure  that  "there have been no  significant  changes in the
Company's internal  controls..." Please revise your disclosure in future filings
to remove the word  significant  and to  discuss  all  changes in your  internal
control over financial  reporting  that have  materially  affected,  or that are
reasonably  likely to materially  affect,  your internal  control over financial
reporting, as required by Item 308 (c) of Regulation S-B.

Response:  We have removed the word  significant from our December 31, 2006 Form
10-KSB/A and will do so in future filings.

Exhibit 31
----------

We note the Section  302  certification  furnished  is not in the proper form as
paragraph 1 improperly references "this quarterly report on Form 10-QSB". Please
amend the filing to present  the  Section  302  certification  set forth in Item
601(b)(31)of  Regulation S-B which properly references the annual report on From
10-KSB.

Response: We have corrected on our December 31, 2006 Form 10-KSB/A.



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As requested, we acknowledge the following:

o    the  company is  responsible  for the  adequacy  of the  disclosure  in the
     filing;
o    the staff  comments or changes to disclosure in response to staff  comments
     do not foreclose the Commission  from taking any action with respect to the
     filing; and
o    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.

Please let us know if you have further comments or need additional clarification
on any of the responses provided.

Sincerely,



Scott A. Haire, President

SAH/ljs










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