April 19, 2006

VIA U.S. MAIL AND FACSIMILE:  (612) 339-4181

Ryan G. Miest, Esq.
Robins, Kaplan, Miller & Ciresi L.L.P.
2800 LaSalle Plaza
800 LaSalle Avenue
Minneapolis, Minnesota 55402-2015
(612) 349-8500

Re:	InfoUSA Inc.
	Definitive Additional Materials filed April 17 and 18, 2006
      File No. 000-19598
      Schedule 13G filed April 12, 2006
      File No.  005-42304

Dear Mr. Miest:

We have reviewed your filings referenced above and have the
following comments.

Schedule 13G/A

1. We note the filing of the amendment on April 12, 2006 of the
Schedule 13G by Mr. Vinod Gupta.  This amendment discloses a
beneficial ownership position in the company of over 40%.  In
2005, the company`s proxy disclosure stated that Mr.Vinod Gupta`s
beneficial ownership percentage was 37.9%.  The difference is the
2.4 million shares held in trust for his adult children and in
certain charitable vehicles, which were only recently disclosed.
The Schedule 13G filed April 12, 2006 states that the "[r]eporting
person`s indirect beneficial ownership of the shares held by the
trust and his spouse, as to which beneficial ownership is
disclaimed, was inadvertently omitted from previous Schedule 13G
filings." Please amend Mr. Gupta`s beneficial ownership report to
identify the number of shares in each separate acquisition by party
(trust or spouse) and the dates on which they were acquired and state
the date the obligation to report such acquisitions was due.

Definitive Additional Materials

2. As you are aware, you must ensure that any allegation is
substantiated.  Characterize each statement or assertion of
opinion or belief as such, and ensure that a reasonable basis for
each opinion or belief exists.  Also refrain from making any
insupportable statements.  Support for opinions or beliefs should be
self-evident, disclosed in the proxy materials or provided to the staff
on a supplemental basis.  The bases for many of the opinions you set
forth in the proxy materials referenced above are not self-evident and
are not disclosed.  Accordingly, and with a view toward additional
disclosure, for each claim you are making in this document, please
state each claim as a belief and provide the staff with annotated
materials adequately supporting each such belief.  Our comments
below incorporate this comment and our comments apply with equal force
to your Memorandum to all Employees and press release filed yesterday
as additional materials.

3. Throughout your proxy materials you several times refer to
Dolphin`s nominees as "hand-picked."  You must explain this
characterization and provide balance.  In this respect we note
that you have never disclosed how the candidates recently appointed to
the board by the board were selected or the participation of Mr. Vinod
Gupta in this process.

4. On page one you state that Dolphin "has launched a hostile
proxy contest."  Since every proxy contest is necessarily in opposition
to management, the use of the word "hostile" should be reconsidered
as it appears to insinuate inappropriate motives.

5. On page one you state that Dolphin became a stockholder "just
months ago."  Please amend this statement to be more specific.  We
understand that Dolphin began to acquire shares in the company on
June 20, 2005, which is nearly ten months ago, as Dolphin
discloses in its proxy materials.  It appears that this requires
correction.

6. On page one you state that Dolphin`s agenda is "misguided."
Explain what this refers to and in what way Dolphin is misguided
in this contest.

7. On page one you state "[i]n fact, we believe the dissident is
trying to win representation on the Board of Directors only to
advance its own misguided and self-serving agenda."  While you
have stated your view in terms of a belief, you provide no reasonable
basis for the assertion that Dolphin`s agenda is in any way self-
serving.   Amend to state why Dolphin has an agenda to advance its
own interests and that it would benefit from the outcome of the
proxy contest other than proportionately as a shareholder of the
company. In this respect, we remind you of your responsibilities
under Rule 14a-9 of the Proxy Rules. Some examples of what, depending
upon particular facts and circumstances, may be misleading within the
meaning of Rule 14a-9 may include material which directly or
indirectly impugns character, integrity or personal reputation, or
directly or indirectly makes charges concerning improper, illegal
or immoral conduct or associations without factual foundation.  See
Note to Rule 14a-9 under Regulation 14A.

8. On page one you state that you have achieved a 17.3% compound
annual rate of revenue growth since 1992.  It appears that it may
be appropriate to state how much of your compound annual rate of
revenue growth is attributable to organic growth and how much to
acquisitions.  In this respect, we note that acquisitions have
been the driving force for much of this growth.  Further, you should
explain why revenue growth is an appropriate metric of value, as
opposed, for example to growth in earnings per share.

9. On page one you reference your four year stock performance,
beginning in December 2001.  Explain why this should be the
relevant period of measurement.

10. On page two you state "By executing our strategy of providing
our customers with a one-stop solution, we can proudly say that we can
offer our customers service that is unparalleled in our industry."
Please provide support for this statement that the company
provides superior services and how you make such statement when it
appears that you are one of the smaller companies when compared to
leading industry players.

11. On page two you state "[w]e have over four million people who
utilize our services - this represents more than the total
customers of all our competitors combined."  Please clarify this
statement. It appears that you may have intended to refer only to
subscription services.  This statement implies that the company is the
largest among its competitors generally and by a wide margin.  Even as
to subscription based services, you should provide support for the
assertion that you have more customers than your competitors
combined.

12. On page three you state "WE BELIEVE THAT DOLPHIN AND ITS HAND-
PICKED NOMINEES REPRESENT ONLY DOLPHIN, NOT THE INTERESTS OF ALL
infoUSA STOCKHOLDERS."  You must provide the basis for this
statement.  In this regard, we note that in its proxy materials,
Dolphin asserts that it has no interest other than as a
Shareholder of the company.  We note another unsupported statement,
commented upon below, to the effect that Dolphin invests for quick and
easy profits and that it is a liquidator.

13. We note your statements on page three that ". . . a forced
sale conducted without regard to market timing, as the dissident seems
to advocate, would produce as great a level of shareholder value as
the continued execution of our strategic plan.  Moreover, uncertainty
caused by the dissident`s intent to put the company up for sale
could cause customers to defect and make it more difficult to attract
new customers."  You must provide the basis for this assertion.  We
note that Dolphin has made the statement on page 2 of its original
preliminary proxy materials that its platform included "reconstituting
the special committee of the board to explore all methods for improving
the Company`s performance and maximizing shareholder value, which could
include a sale of the Company" (emphasis added).  It appears that
consideration of all strategic alternatives has been an expressed
goal of Dolphin, one of which may be a sale.  If you have some other
basis for your belief you need to provide it.

14. Explain how Dolphin`s "interference could also impede your
efforts to attract and retain talented employees in key
positions," as stated on page three.

15. We note your statement on page three that you "believe that
the dissident`s track record of investing for quick and easy profits
clearly shows that they have never created value, only liquidated
it. Please provide support for this statement.  We believe that you
should provide examples.  As currently stated, there is no factual
support for this statement.

16. On page three you remark that Dolphin`s nominees have no
"relevant operational experience."  You should provide balance in
making such assertions.  For example, this statement implies that
the company believes that having relevant operational experience,
which we assume means experience in the company`s particular industry,
is an important criteria for board membership.  The most recent
addition to your board is Bernard Reznicek whose biography does not
indicate relevant operational experience.  Explain what you mean by
"relevant operational experience" and why Mr. Reznicek satisfies this
criteria any more than Dolphin nominees.

17. On page three you accuse Dolphin of making "misleading
suggestions."  Provide your examples of what those misleading
suggestions comprise.

18. We note your statement on page four that "YOUR BOARD AND
MANAGEMENT IS DEDICATED TO SOUND CORPORATE GOVERNANCE. . . ."
Please provide the basis for this statement and describe how the board
or management manifests its dedication to good governance.  In this
respect, we note that Dolphin has identified various governance
issues in its proxy solicitation materials and other public
announcements, including the exemption of Mr. Vinod Gupta and his
affiliates from the company`s shareholder rights plan, oversight
of the use of the company assets for personal executive benefit, and
the dissolution of the special committee formed to evaluate Mr. Vinod
Gupta`s going private bid.  Also, we note that the Corporate
Library, an independent governance evaluation organization, has recently
assigned a "D" governance rating to infoUSA.

19. On page four we note your statements that "Mr. Gupta owns more
than 40% of the company`s outstanding shares, and other members of
the senior management team and the Board also have considerable
holdings.  Clearly, the interests of the management are aligned
with those of all stockholders."   Explain how Mr. Vinod Gupta`s
interests are aligned with those of all shareholders.  It is not clear
or self evident to us that the interests of management are aligned with
those of all stockholders.  We note the recent history, in July 2005, of
Mr. Vinod Gupta`s proposal to acquire the company being rejected
by an independent committee of the board.

20. We note your statement, on page four, that "[a]s demonstrated
by the decision last year to reject the going private proposal, the
Board is independent and acts in the best interests of
stockholders." We believe that this statement, paired with the claim that
Mr. Vinod Gupta owns more than 40% of the company . . . . and clearly the
interests of management are aligned with all shareholders, lacks
balance.  In that respect, in discussing the board`s independence
vis-a-vis the decision to reject last years going private
proposal, we believe that you should state that it was a special committee
of the board that voted to reject Mr. Vinod Gupta`s proposal.
Further, some relevant facts include (i) that the committee was disbanded
by the board on a split vote one day after the company issued a
release that the work of the board would continue, (ii) that each member
of the special committee either voted against disbanding the
committee, or in one case, abstained and (iii) it appears that the vote
to disband the committee passed because of the vote of Mr. Vinod
Gupta, the Company`s outside counsel and another member of the board who
served as a director of mutual funds affiliated with Mr. Vinod
Gupta. Please amend to provide balance in your disclosure of this matter.

21. On page four you state that you "believe that the dissident`s
nominees only commitment is to its own short-term agenda."  Please
provide the factual basis for this belief.

      As appropriate, please amend your filing.  You may wish to
provide us with marked copies of the amendment to expedite our
review.  Please furnish a cover letter, marked as correspondence
on EDGAR with your amendment that keys your responses to our comments
and provides any requested information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your amendment and responses
to our comments.

	Please contact me at (202) 551-3257, or by facsimile at (202)
772-9203 with any questions.

Very truly yours,


Celeste M. Murphy,
Special Counsel
Office of Mergers and Acquisitions