UNIFY CORPORATION
2102 Arena Boulevard
Sacramento, California 95834
October 10, 2005
VIA FEDERAL EXPRESS AND DIRECT TRANSMISSION
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Re: Unify Corporation (the “Company”)
Form 10-K for the Fiscal Year Ended April 30, 2005
Filed July 28, 2005
Form 8-K
Filed September 1, 2005
File No. 1-11807)
Ladies and Gentleman:
With respect to the letter of comments received from the staff of the Commission in regards to the above-referenced filings and our responses thereto, the Company hereby acknowledges that:
• Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings;
• The Company is responsible for the adequacy and accuracy of the disclosure in the filings; and
• the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Thank you for your assistance. If you should have any questions, please call Kevin Coyle of DLA Piper Rudnick Gray Cary US LLP, counsel to the Company, at 916-930-3240.
| Very truly yours, |
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| UNIFY CORPORATION |
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| By: | /s/ TODD E. WILLE | |
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| | Todd E. Wille |
| | Chief Executive Officer |
cc: Stathis Kouninis, Securities and Exchange Commission
Kevin Coyle