Mail Stop 4561 							March 15, 2006 Mr. Yorgen H. Edholm President and Chief Executive Officer I-Many, Inc. 399 Thornall Street 12th Floor Edison, New Jersey 08837 	Re:	I-Many, Inc. 		Form 10-K for Fiscal Year Ended December 31, 2004 		Form 10-Q for Fiscal Quarter Ended March 31, 2005 		Form 10-Q for Fiscal Quarter Ended June 30, 2005 		Form 10-Q for Fiscal Quarter Ended September 30, 2005 File No. 000-30883 Dear Mr. Edholm: We have completed our review of your Form 10-K and related filings and do not, at this time, have any further comments 								Sincerely, 								Stephen Krikorian 								Accounting Branch Chief