October 4, 2005 Peter DiIorio peter.diiorio@hellerehrman.com Main (212) 832-8300 Via Edgarlink Fax (212) 763-7600 Securities and Exchange Commission Division of Corporation Finance Mail Stop - 4561 100 F Street, N.E. Washington, DC 20549 Attention: Ms. Sara Kalin Re: Convera Corporation Form S-3 Registration Statement File No. 333-127222 Dear Ms. Kalin: Enclosed on behalf of Convera Corporation (the "Company") is an acceleration request executed on behalf of the Company, which requests that the Securities and Exchange Commission take appropriate action to make the above-captioned Registration Statement effective at 5:30 PM Washington, D.C. local time on October 6, 2005, or as soon thereafter as possible. In addition, as discussed, the Company confirms that in future filings on Form 10-K and Form 10-Q, the Company's disclosure with respect to its evaluation of disclosure controls and procedures will more closely conform with the language of Rule 13a-15(e) under the Securities Exchange Act of 1934. If you have any questions concerning any of the foregoing, please call the undersigned at (212) 847-8711. Sincerely, /s/ PETER DIIORIO Peter DiIorio Heller Ehrman LLP