Andrews Kurth LLP 1717 Main Street, Suite 3700 Dallas, Texas 75201 214.659.4400 Phone 214.659.4401 Fax andrewskurth.com April 8, 2005 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Jeffrey Werbitt, Mail Stop 4-6 Re: Assure Data, Inc. Amendment No. 3 to Registration Statement on Form SB-2 Filed on April 8, 2005 File No. 333-123347 Assure Data, Inc. is filing on this date its Amendment No. 3 to the above-captioned Registration Statement. Set forth below are the comments received from the Staff of the Commission by letter dated March 16, 2005, and under each comment the Company's response and cross reference to its treatment in the Amendment. We have assisted the Company in answering the comments. Complimentary copies of this letter and the Amendment, both clean and marked to show changes, are being delivered contemporaneously herewith, to Melissa Walsh and Jeffrey Werbitt. General - ------- 1. Please update your financial statements in accordance with Item 310(g) of Regulation S-B. Also include a currently dated consent pursuant to Item 601(b)(23) of Regulation S-B. The financial information has been updated to December 31, 2004, and a current consent is attached as Exhibit 23.1 Sincerely yours, /s/ Ronald L. Brown Ronald L. Brown RLB:chm cc: Assure Data, Inc. Tschopp, Whitcomb & Orr, PA