WORLDWIDE
                                STRATEGIES, INC.
            3810 E. FLORIDA AVE., SUITE 400 * DENVER, COLORADO 80210
                        TEL 303.991.5887 * 303.991.5888





May 5, 2006


Mr. Michael Clampitt, Senior Attorney
Division of Corporation Finance
Mail Stop 4561
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

RE:      WORLDWIDE STRATEGIES INCORPORATED
         REGISTRATION STATEMENT ON FORM SB-2
         FILE NO. 333-129398

Dear Mr. Clampitt:

On behalf of Worldwide Strategies Incorporated, I hereby request acceleration of
the effective date of the above-referenced registration statement to May 9,
2006, or the earliest practicable date thereafter.

In making this request, Worldwide Strategies Incorporated (the "Company")
acknowledges that:
    o    should the Commission or the staff, acting pursuant to delegated
         authority, declare the filing effective, it does not foreclose the
         Commission from taking any action with respect to the filing;
    o    the action of the Commission or the staff, acting pursuant to delegated
         authority, in declaring the filing effective, does not relieve the
         Company from its full responsibility for the adequacy and accuracy of
         the disclosure in the filing; and
    o    the Company may not assert this action as a defense in any proceeding
         initiated by the Commission or any person under the federal securities
         laws of the United States.

Sincerely,

/s/ W. EARL SOMERVILLE

W. Earl Somerville
Chief Financial Officer