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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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February 5, 2008
United States
Securities and Exchange Commission
Washington, DC 20549
Mail Stop 6010

Re: SEC comment letter dated February 1, 2008

Dear Mr. Kuhar:

In  reference  to your  letter of February  1, 2008 we  respectively  submit the
following.

Form 10-KSB/A for the Fiscal Year Ended December 31, 2006.
Item 8A. Controls and Procedures, Page 24
-----------------------------------------

1.  Please  refer to prior  comment 2. We note your  response to you comment and
amendment  to  the  filing  which  disclosed  that  "there  were  no  changes...
subsequent to the date of such  evaluation."  Please  revise your  disclosure in
future  filings to disclose any changes in your internal  control over financial
reporting that occurred  during the most recent fiscal  quarter that  materially
affected,  or is reasonably likely to materially  affect,  your internal control
over financial reporting as required by Item 308(c) of Regulation S-B.

Response: We will do so in future filings.

Index to Exhibits, page 34
--------------------------

2.  Please  refer to prior  comment 3. We note your  response to our comment and
amendment   to  the  filing   which   includes   Section  302  and  Section  906
certifications  dated as of the  original  filing  date of the Form  10-KSB/A of
March 26,  2007.  Please  amend the  filing to include  the  entire  text of the
corrected   annual   report   currently   dated  Section  302  and  Section  906
Certifications.

Response: We have made the corrections on the filing.

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

Sincerely,
/s/ Scott A Haire
-----------------
Scott  A. Haire, President






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