Convera Corporation
                          1921 Gallows Road, Suite 200
                             Vienna, Virginia 22182





October 4, 2005


Via Edgarlink
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC  20549
Attention:        Ms. Sara Kalin


Re:      Convera Corporation
         Registration Statement on Form S-3
         File No. 333-127222

Dear Ms. Kalin:

     Pursuant to Rule 461 under the Securities Act of 1933, as amended,  Convera
Corporation (the "Company") hereby requests that the 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.

     Pursuant to the  comments of the  Commission  set forth in the letter dated
August 19, 2005 in connection with the above-captioned  Registration  Statement,
the Company acknowledges that:

     -    should the  Commission  or the Staff,  acting  pursuant  to  delegated
          authority,  declare the Registration Statement effective,  it does not
          foreclose  the  Commission  from taking any action with respect to the
          Registration Statement;

     -    the  action  of  the  Commission  or the  Staff,  acting  pursuant  to
          delegated   authority,   in  declaring  the   Registration   Statement
          effective,  does not relieve the Company from its full  responsibility
          for the adequacy and accuracy of the  disclosure  in the  Registration
          Statement; and

     -    the Company may not assert this action as a defense in any proceedings
          initiated by the Commission or any person under the federal securities
          laws of the United States.

     Should you have any questions or comments  regarding the foregoing,  please
contact me at (703) 760-4080.


                                   Sincerely,

                                   Convera Corporation


                                   /s/ JOHN R. POLCHIN
                                   John R. Polchin
                                   Chief Financial Officer



cc:      Mr. Stephen M. Davis and Mr. Peter DiIorio (Heller Ehrman LLP)