Mail Stop 4561

June 27, 2005


      VIA USMAIL and FAX (972) 250 - 0934

Mr. Gary W. Boyd
Vice President - Finance and Chief Financial Officer
Ascendant Solutions, Inc.
16250 Dallas Parkway, Suite 102
Dallas, Texas 75248

      Re:	Ascendant Solutions, Inc.
		Form 10-K for the year ended 12/31/2004
      Filed 3/29/2005
      Form 10-Q for the period ended 3/31/2005
      Filed 5/12/2005
      File Nos. 000-27945

Dear Mr. Gary W. Boyd:

      We have reviewed your filings and have the following
comments.
We have limited our review to only the issues addressed below and
will make no further review of your documents.  As such, all
persons
who are responsible for the adequacy and accuracy of the
disclosure
are urged to be certain that they have included all information
required pursuant to the Securities Exchange Act of 1934.

      Where indicated, we think you should revise your documents
in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comments are inapplicable or a revision
is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

Financial Statements and Notes

Note 1 - Organization and Significant Accounting Policies

Significant Accounting Policies

Basis of Presentation, page 46

1. We note that you consolidate entities for which you have
significant influence over operations. Please, explain to us in
sufficient details your consolidation policy and what significant
influence over operations means, as used in your consolidation
policy.  Also, explain to us your basis for consolidating your 50%
interest in Fairways Frisco, as it appears from the disclosure in
the
tables on pages 45-46. Please refer us to the GAAP literature that
supports your consolidation policy.

Fairways Frisco Partnerships, pages 54 - 56
2. We note that Fairways Frisco has agreed to make additional
capital
contributions to fund payment of expenses and repayment of loans.
Tell us how you considered paragraph 5 of FIN 46(R) in accounting
for
the Company`s investment in Fairways Frisco Partnerships.
3. We note that the information presented in the table on page 56
is
as of a date subsequent to your accountants` report. Please revise
the document to clarify this apparent conflict.

Note 9 - Investment In Limited Partnerships
4. Given the significance of investment income for the year ended
December 31, 2004,   tell us how you considered paragraph 20(d) of
APB 18 and Rule 3-09 of Regulation S-X in disclosing information
related to your investments in limited partnerships.









Form 10-Q for the Quarter Ended March31, 2005

Note 2 - Description of Business

Significant Accounting Policies

Investment in Limited Partnerships, page 6

5. We note that you utilize the cost method to account for your
investment in Fairways Frisco, L.P. We also note on page 10 (note
10)
and elsewhere in the filing that your ownership interest in this
entity is more than 3%. Explain to us how you considered EITF
Topic
D-46 in reaching your conclusion with respect to the cost method
of
accounting.


*    *    *    *


      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please furnish a cover letter with your
amendment
that keys your responses to our comments and provides any
requested
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* 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; 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

	You may contact Wilson K. Lee, at (202) 551-3468 or me, at
(202)
551-3414 if you have questions.



								Sincerely,



      Jorge Bonilla
      Senior Staff Accountant



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Gary W. Boyd
Ascendant Solutions, Inc.
June 27, 2005
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