Victoria C. Mitchell vmitchell@velaw.com
Tel 214.220.7827Fax 214.999.7827
November 9, 2005
VIA EDGAR CORRESPONDENCE
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Filing Desk
| Re: | MetaSolv, Inc. |
Ladies and Gentlemen:
On behalf of MetaSolv, Inc. (the “Company”), we submit to you the Company’s Registration Statement on Form S-3 registering 11,500,000 shares of common stock of the Company. Pursuant to Rule 461(a) under the Securities Act of 1933 (the “Securities Act”), the Company intends to request acceleration of the effective date of the Registration Statement orally. The Company has indicated that it is aware of its obligations under the Securities Act.
The Company has transmitted payment of the required filing fee in the amount of $3,756.10 for the Registration Statement by wire transfer on November 9, 2005 to the Commission’s account at Mellon Bank in Pittsburgh, Pennsylvania.
The Company respectfully requests that the Staff direct any questions or comments to the undersigned at (214) 220-7827.
Very truly yours, |
| /s/ VICTORIA MITCHELL |
| Victoria Mitchell |
cc: Jonathan K. Hustis, MetaSolv, Inc. |
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