| | |
 | | JDA Software Group, Inc. 14400 N. 87th Street Scottsdale, Arizona 85260 www.jda.com +1.480.308.3460 main +1.480.308.4268 fax |
December 20, 2011
VIA EDGAR
Patrick Gilmore
Accounting Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-5720
Re: | JDA Software Group, Inc. |
| Form 10-K for the Fiscal Year Ended December 31, 2010 |
Dear Mr. Gilmore:
Reference is made to the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission, addressed to JDA Software Group, Inc. (the “Company”, “we” or “us”) regarding its Form 10-K for the Fiscal Year Ended December 31, 2010, as filed March 1, 2011, and its Form 8-K filed June 1, 2011, File No. 000-27876. We reviewed the Staff’s comments and noted that the Staff requested we respond within ten business days or advise the Staff when we will provide the requested response. Please be advised that the Company’s accounting personnel are engaged in year-end matters, and will not be able to fully address the Staff’s comments until after the first of the year. Accordingly, we respectfully notify the Staff that we intend to respond to its comments no later than January 20, 2012, and we will advise the Staff of our progress in the middle of January. If you have any comments or questions, please direct them to me at (480) 308-3460.
Sincerely,

G. Michael Bridge
Senior Vice President, General Counsel
cc: | Pete Hathaway, JDA Software Group, Inc. |