October 30, 2006
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attention: Ms. Kathleen Collins
| Re: | Comment Letter Dated October 2, 2006 |
Epicor Software Corporation
Form 10-K for the Fiscal Year Ended December 31, 2005
Filed March 31, 2006
Form 10-K/A for the Fiscal Year Ended December 31, 2005
Filed April 14, 2006
Form 10-Q for the Quarterly Period Ended June 30, 2006
Filed August 9, 2006
File No. 0-20740
Ladies and Gentlemen:
We refer to Ms. Collins letter dated October 2, 2006 which sets forth the comments of the staff of the Securities and Exchange Commission (the “Staff”) regarding the Form 10-K for the year ended December 31, 2005, the Form 10-K/A for the fiscal year ended December 31, 2005 and the Form 10-Q for the quarterly period ended June 30, 2006 of Epicor Software Corporation (the “Company”). The Company hereby requests an additional 5 business days to respond to the Staff’s comments. As discussed with Ms. Collins, the Company intends to respond to the Staff’s comments by November 6, 2006.
If you have any questions, please do not hesitate to call Katharine Martin at Wilson Sonsini Goodrich & Rosati at (650) 565-3522.
| Sincerely, |
/s/ John D. Ireland |
| John D. Ireland |
| Senior Vice President and General Counsel |
| Epicor Software Corporation |
