Mail Stop 4561 								October 19, 2005 Richard Rudman President and Chief Executive Officer Vocus, Inc. 4296 Forbes Boulevard Lanham, MD 20706 Re: 	Vocus, Inc. 	Amendment No. 4 to Form S-1 	Filed on October 11, 2005 	File No. 333-125834 Dear Mr. Rudman: 	We have reviewed your responses and have the following comment. Vocus, Inc. and Subsidiaries Consolidated Financial Statements Notes to Consolidated Financial Statements Note 3. Acquisitions, page F-13 1. In response to prior comment No.18 from our letter dated July 15, 2005, you indicated that you would disclose in MD&A the factors contributing to the difference between the fair value at each grant date and the estimated IPO price per paragraph 180(b) of the Practice Aid. We note that such disclosure is absent in the most recent amendment filed. Revise accordingly. 	As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. We may have additional comments based on reviewing your amendment and responses to our comments. 	You may contact Morgan Youngwood at 202-551-3479 or Melissa Walsh at 202-551-3224, if you have questions regarding comments on the financial statements and related matters. Please address all other comments to Maryse Mills-Apenteng at 202-551-3457. If you require further assistance you may contact the undersigned at 202- 551-3730. 								Sincerely, Barbara C. Jacobs 								Assistant Director cc:	Stephen A. Riddick, Esq. Greenberg Traurig, LLP 	800 Connecticut Avenue, N.S. Suite 500 	Washington, D.C. 20006 ?? ?? ?? ?? Richard Rudman Vocus, Inc. October 19, 2005 Page 2