May 27, 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 | |
| Form 10-Q for the Quarterly Period ended September 30, 2008 | |
| Filed November 14, 2008 | |
| Form 10-K for the Fiscal Year ended December 31, 2008 | |
| Filed April 15, 2009 | |
| File No. 000-28685 |
We have reviewed your follow-up comments in your most recent letter dated May 12, 2009, which is related to your original comment letter dated November 14, 2008. Due to the timing of our receipt of the letter on May 12, 2009 falling during the period we were preparing our Form 10-Q Report for the three months ended March 31, 2009, and also 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 21 business days to complete the Company’s responses to the Commission’s most recent Comment Letter. The granting of our request would make our responses to the Commission’s most recent Comment Letter due on or before June 25, 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
Chief Financial Officer
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 |