CATUITY, INC.

                                December 21, 2005


Ms. Barbara C. Jacobs                                              Via Facsimile
Mr. Daniel Lee
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549


         Re:      Catuity, Inc., Registration Statement on Form S-3 for
                  1,048,480 shares of common stock (Registration No: 333-128600)

Dear Ms. Jacobs and Mr. Lee:

         Pursuant to Rule 461, request is hereby made that the above-referenced
registration statement (the "Registration Statement") be declared effective by
the end of the business day on Friday, December 23, 2005 or as soon thereafter
possible. The undersigned is aware of the responsibilities under the Securities
Act of 1933 and the Securities Exchange Act of 1934 as they relate to the
proposed public offering of the securities specified in the above-referenced
registration statement. In addition, the Company acknowledges that:

- -      Should the Securities and Exchange Commission (the "Commission") or its
       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 filing;

- -      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 filing, and

- -      The Company may not assert the staff comments and the declaration of
       effectiveness as a defense in any proceeding initiated by the Commission
       or any person under the federal securities laws of the United States.

         Thank you.

                                     Very truly yours,

                                     CATUITY, INC.


                                     By: /s/ JOHN H. LOWRY
                                         ---------------------------------------
                                         John H. Lowry, Chief Financial Officer