September 16, 2005

Mail Stop 4561

Bobby Yazdani
CEO and Chairman
Saba Software, Inc.
2400 Bridge Parkway
Redwood Shores, California 94065-1166

Re:	Saba Software, Inc.
	Registration Statement on Form S-3/A
	Filed August 31, 2005
	File No. 333-125778

	Form 10-K for the fiscal year ended May 31, 2005
	File No. 0-30221

Dear Mr. Yazdani:

	This is to advise you that we have limited our review of your
filings to the significance of the THINQ acquisition,
identification
of selling security holders and disclosure in your periodic report
in
response to Items 307 and 308(c) of Regulation S-K.  Where
indicated,
we think you should revise your documents in response to these
comments.

Selling Security Holders, page 11

1. You disclose in this section and in your response to comment 2
of
our letter dated July 13, 2005 that you will provide a post-
effective
amendment or prospectus supplement to include information
concerning
selling security holders not identified in your selling security
holder table.  As you are aware, only security holders that are
named
as selling security holders or transferees, donees and pledgees of
those named holders can use this prospectus.  Information
regarding
other selling security holders that are unnamed in the prospectus
prior to effectiveness, may only be added by post-effective
amendment
to the registration statement.  Please revise your registration
statement to clarify.
2. We refer to your response to comment 3 of our letter dated July
13, 2005.  Please revise your document to indicate clearly in this
section that none of your selling security holders are broker-
dealers.  Please identify in this section which selling security
holders are affiliated with registered broker-dealers and briefly
describe the affiliation.  Finally, revise to state per your
supplemental response that at the time of the purchase of the
securities to be resold the selling security holder had no
arrangements or understandings, directly or indirectly, with any
person to distribute the securities.
3. We refer you to your response to comment 4 of our letter dated
July 13, 2005. Please provide additional supplemental information
on
the selling security holder with an open position.  Please advise
as
to the name of the entity, the number of shares to be resold and
the
position he maintains as of a practicable date prior to responding
to
this comment.

Exhibits
4. Please file a more recently dated legal opinion.

Form 10-K for the fiscal year ended May 31, 2005

Controls and Procedures, page 61
5. We refer you to comment 5 of our letter dated July 13, 2005. We
note your disclosure that your "Chief Executive Officer and Chief
Financial Officer have concluded that the Company`s disclosure
controls and procedures were effective as of May 31, 2005 to
ensure
that information required to be disclosed by the Company in
reports
that it files or submits under the 1934 Act is recorded,
processed,
summarized and reported within the time periods specified in
Securities and Exchange Commission rules and forms."  Please
advise,
if true that your officers concluded that your disclosure controls
and procedures are also effective to ensure that information
required
to be disclosed in reports that you filed or submit under the
Exchange Act is accumulated and communicated to your management
including you chief executive and chief financial officer, to
allow
timely decisions regarding required disclosure.  See Exchange Act
Rule 13a-15(e).

* * * * *

	If you have any questions, please call Adam Halper, at (202)
551-3482 or Perry Hindin, at (202) 551-3444.  If you require
additional assistance you may contact me, at (202) 551-3462 or in
my
absence Barbara C. Jacobs, Assistant Director at, (202) 551-3730.

								Sincerely,


								Mark P. Shuman
								Branch Chief - Legal



cc:	Via Facsimile
      Peter E. Williams III, Chief Financial Officer
      Fax: (650) 581-2599
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Bobby Yazdani
Saba Software, Inc.
September 16, 2005
Page 1