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                         October 21, 2005

United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Room 4561
Washington, D.C. 20549

Attention:  Mark P. Shuman, Branch Chief - Legal
            Daniel Lee, Staff Attorney

Re:         Pacific WebWorks, Inc.
            Registration Statement on Form SB-2 filed August 31, 2005, as
            amended
            File No. 333-127995

Dear Mr. Shuman,

Pacific WebWorks, Inc. (the "Company") requests acceleration of the effective
date of the above identified registration statement and requests that the
registration statement be given an effective date of Wednesday, October 26,
2005, at 4:00 p.m. Eastern Time, or as soon thereafter as reasonably
practicable.

The Company is aware of its 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 identified registration
statement.

The Company acknowledges that

..     should the Securities and Exchange Commission (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;

..     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

..     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.


                                                           Voice: 801-578-9020
                                                 180 South 300 West, Suite 400
                                                    Salt Lake City, Utah 84101
                                                        www.pacficwebworks.com
                                                             fax: 801-578-9019






Mark P. Shuman
October 21, 2005
Page 2



Please call the Company's counsel, Cindy Shy, at (435) 674-1282, if you have
any problems or concerns with this request for acceleration.  When
effectiveness of the registration statement is granted, please inform her of
the granted effective date and time.  Thank you for your attention to this
matter.


                                             Sincerely,


                                             /s/ Kenneth W. Bell

                                             Kenneth W. Bell
                                             Chief Executive Officer