Robert G. Schwartz, Jr.
I-many, Inc.
399 Thornall Street
Edison, NJ 08837
February 17, 2006
United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street
Mail Stop 4561
Washington, D.C. 20549-4561
Attention: Mr. Stephen Krikorian
| Re: | I-many, Inc. |
| Form 10-K for the Fiscal Year Ended December 31, 2004 |
| Form 10-Q for the Fiscal Quarter Ended March 31, 2005 |
| Form 10-Q for the Fiscal Quarter Ended June 30, 2005 |
| File No. 0-30883 |
Dear Mr. Krikorian:
On behalf of I-many, Inc. (the “Company”), and in furtherance of my verbal request to Chris White of the staff of the Commission today, I hereby request a second extension of the deadline for the Company to respond to the comments provided by the staff in a letter dated January 13, 2006. With your permission, we would like to extend the deadline to February 24, 2006. The Company’s auditor has requested the extra time in order to complete its review of the current draft of the Company’s response letter.
Please call me at (207) 228-2298 if you would like further information regarding the foregoing.
Very truly yours,
/s/ Robert G. Schwartz, Jr.
Robert G. Schwartz, Jr.
Vice President and General Counsel
