February 10, 2009
| To: | Division of Corporation Finance |
| Securities and Exchange Commission |
| From: | Vertical Computer Systems, Inc. |
| Re: | Vertical Computer Systems, Inc. |
| Form 10-KSB for the Fiscal Year ended December 31, 2007 | |
| Filed April 22, 2008 | |
| Form 10-Q for the Quarterly Period ended June 30, 2008 | |
| Filed August 19, 2008 | |
| File No. 000-28685 |
We have reviewed your follow-up comments in your letter dated January 30, 2009 related to your original comment letter dated November 14, 2008. Because of the complexity of some of your comments, we need to retain additional consulting and legal advice. Therefore, we respectfully request an extension of an additional 15 business days to complete the Company’s responses to the Commission’s Comment Letter dated January 30, 2009. The granting of our request would make our responses to the Commission’s Comment Letter due on or before February 27, 2009. We will do whatever we are able to do to conclude our responses before that date, but because of the need to coordinate various third parties whose schedules we cannot control, we are requesting the additional time.
Sincerely,
/s/ David Braun
David Braun
CFO, Vertical Computer Systems, Inc.
| http://www.vcsy.com | 101 W. Renner Road, Suite 300▪ Richardson, TX 75082 | |
| Email: corporate@vcsy.com | Tel: (817) 348-8717 ▪ Fax: (512) 692-1836 |