VIA NET.WORKS, INC.
H. Walaardt Sacrestraat 401-403
1117 BM Schiphol
The Netherlands
September 16, 2005
BY EDGAR
The Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: VIA NET.WORKS, Inc. (the “Company”)
Dear Secretary:
In connection with the filing of the Company’s Proxy Statement on Form 14A, the Company’s hereby acknowledges: (i) the Company is responsible for the adequacy and accuracy of the disclosure in its filings (the “Filings”) with the Securities and Exchange Commission (the “Commission”); (ii) comments of the staff of the Commission (the “Staff”) or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the Filings; and (iii) the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.
| VIA NET.WORKS, Inc. |
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| By: | /s/ Matt Nydell | |
| Name: Matt Nydell |
| Title: Senior Vice President, General Counsel and Secretary |