Convera Corporation 921 Gallows Road, Suite 200 Vienna, Virginia 2182 (703) 761-3700 June 15, 2006 Via Edgar Securities and Exchange Commission Division of Corporation Finance Mail Stop - 4561 100 F Street, N.E. Washington, DC 20549 Attention: Ms. Barbara C. Jacobs, Ms. Maryse Mills-Apenteng and Ms. Anne Nguyen Re: Convera Corporation Form S-3 Registration Statement File No. 333-133344 Dear Ladies and Gentlemen: 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 4:00 PM Washington, D.C. local time on June 16, 2006, or as soon thereafter as possible. Pursuant to the comments of the Commission set forth in the letter dated May 11, 2006 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) 761-3700. Sincerely, Convera Corporation /s/ John R. Polchin John R. Polchin Chief Financial Officer NY 631762 v1 6/15/06 3:13 PM (33594.1001)