SecProbe.io

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MB                                          2225 East Randol Mill Road Suite 305

                                            Arlington, Texas 76011
SOFTWARE CORPORATION                        (817) 633-9400    FAX (817) 633-9409
--------------------------------------------------------------------------------

September 9, 2005

United States
Securities and Exchange Commission
Washington, DC 20549
Mail Stop 6010

Re: SEC comment letter dated July 5, 2005

Dear Mr. Kuhar:

In  reference  to your  letter  of  July 5,  2005  we  respectively  submit  the
following.

Form 10-KSB for the Fiscal Year Ended December 31, 2004.
--------------------------------------------------------

Item 8A. Controls and Procedures, Page 9.
-----------------------------------------

1. We note your disclosure that your principal  executive  officer and principal
financial officer have evaluated your disclosure controls and procedures as of a
date within 90 days before the filing date of your annual report.  Please revise
future filings to disclose  management's  conclusion regarding the effectiveness
of your  disclosure  controls and procedures as of the end of the period covered
by the  annual  report.  Refer to Item 307 of  Regulation  S-B and Part III.F of
Management's   Reports  on  Internal   Control  Over  Financial   Reporting  and
Certification  of  Disclosure  in Exchange  Act  Periodic  Reports,  Release No.
33-8238.

Response:  We have corrected on our June 30, 2005 Form 10-QSB.  Please review to
make sure we have complied.

2. In  future  filings  please  revise  the  language  used  in your  disclosure
concerning changes in your internal control over financial reporting to indicate
whether there was any changes to your internal control over financial  reporting
that has materially affected, or that is reasonably likely to materially affect,
your internal  control over financial  reporting,  consistent  with the language
used in amended Item 308(c) of Regulation S-B.

Response:  We have corrected on our June 30, 2005 Form 10-QSB.  Please review to
make sure we have complied.

Report of Independent Register Public Accounting Firms, Page F-2
----------------------------------------------------------------

3. We note that your corporate  headquarters  is located in Arlington,  TX, your
operations are based in Ft.  Lauderdale,  FL and your accountants are located in
Phoenix, AZ. Please tell us why your auditor is from Arizona given the locations
of your headquarters and operations.  While we note your auditors are registered

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with PCAOB,  tell us if they are  licensed to practice in Florida and Texas.  If
not, tell us why you believe they were qualified to perform the audit.

Response:  Clancy and Co.,  P.L.L.C.,  our independent  auditors are licensed in
Texas,  where our corporate  headquarters  are located and all of our accounting
operations  are  performed.  The  Company's  operations in Ft.  Lauderdale,  FL,
essentially  consist of office space leased for our sales force for our product.
The Company's product inventory is located in a warehouse  distribution facility
in Rochester, New York.

Financial Statements
--------------------

Note 3- Business Acquisition, Page F-11
---------------------------------------

4. We see that on August 20, 2004 you  acquired  all of the  outstanding  equity
interests  in Wound  Care  Innovations,  LLC  ("WCI") in  consideration  for the
issuance of 6,000,000  shares of restricted  stock.  It appears that MB Software
and WCI are under the "common  control" of Mr. Cossutta and Mr. Haire as defined
by paragraph 3 of EITF 02-05.  If our  presumption  is correct,  tell us why the
transaction was not accounted for as the reorganization of entities under common
control,  i.e.,  in a manner  similar  to a  polling  of  interest  with  assets
transferred  at their  historical  costs as required by paragraphs D11 to D17 of
SFAS 141. Please tell us your  consideration  of this accounting  basis for this
transaction and specifically address your consideration of the common control of
MB Software and WCI. If you have  appropriately  concluded  the entities are not
under common control,  please explain to us what consideration you have given to
paragraphs 15 to 19 of SFAS 141 in  identifying  the acquiring  entity.  Tell us
whether  you  believe  the  transaction  should  be  accounted  for as a reverse
acquisition or recapitalization.  Please support your assertions with references
to the  authoritative  accounting  guidance  upon which you relied.  We may have
additional comments after reviewing your response.

Response: Mr. Cossutta and Mr. Haire are the controlling  shareholders of MB and
WCI,  however the product and the actual patent holder were controlled and owned
by an unrelated party with which WCI had entered into a Distribution  Agreement.
Accordingly,  the  acquisition  of WCI was  effected  by MB for the  purpose  of
obtaining the exclusive rights to the product and patent. We did not account for
the  transaction as a  reorganization  of entities under common control for this
reason,  but instead  considered the transaction an  acquisition,  accounted for
under the purchase  method of  accounting  because MB acquired the net assets of
WCI and obtained  control  over its net assets.  (FAS 141,  paragraph  9). MB is
considered  the acquiring  entity in this case as it issued its common shares as
consideration  in exchange for 100%  acquisition  interest in WCI. MB ultimately
controls  the  operating  and  financing  decisions  of the  resulting  combined
entities  as MB's  president  and board of  directors  hold a  majority  of MB's
outstanding  common stock.

The cost of the acquired entity (WCI) was determined by the fair market value of
the 6M securities  issued as  consideration,  as determined by published  quoted
market prices.  Since no cash was exchanged in the transaction,  the measurement
was based on the fair value of the securities issued,  since it was more clearly
evident and, thus, more reliably measurable. (FAS 141, paragraph 6)

Note 4 - Related Party Transactions, page F-12
----------------------------------------------

5. We see that you have engaged in various  transactions  with related  parties,
including the acquisition of WCI and borrowings from related  entities.  Related
party transactions should be identified and the amounts separately stated on the

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face of the  income  statement  or balance  sheet,  if  material.  Additionally,
paragraphs  2 to 4 of  SFAS 57  require  the  disclosure  of the  nature  of the
relationships, a description of transactions, the dollar amount of transactions,
the  amounts  due to or from  related  parties  and also the  nature of  control
relationships  between related parties even if there are no transactions between
the  enterprises.  In  accordance  with SFAS 57,  please tell us more about your
related  party   transactions   and  update  future  filings  to  disclose  this
information.

Response:  We have added the  additional  disclosure  on our June 30,  2005 Form
10QSB. Due to related parties at December 31, 2004, represents the following:

           Related party                     Nature of relationship         Description of transaction   Amounts due from
                                                                                                               (to)
                                                                                                          related parties
------------------------------------- ------------------------------------- --------------------------- --------------------
<S>                                   <C>                                   <C>                         <C>
HEB, LLC, a Nevada Limited            Scott Haire, Chairman President,      Series of funds advanced    $             70,905
Liability Company                     CEO and CFO of this company,          for working capital
                                      controls both entities financing      purposes
                                      and operating decisions
Araldo Cossutta, an individual        Director  and   stockholder  of  the  Funds advanced for                       (76,271)
                                      Company                               working capital purposes
eAppliance Payment Solutions,         Controlling   owners  in  eAppliance  Series of funds advanced                  (2,568)
LLC a Nevada Limited Liability        Payment Solutions, LLC are the        for working capital
Company                               President  and  one  director  of MB  purposes
                                      Software Corporation
Virtual  Payment  Solutions,  LLC     Scott     A.     Haire     is    the  Series of funds advanced                  22,630
a Nevada Limited Liability            Manager/Member   of  this   company,  for working capital
Company                               controls both entities financing and  purposes
                                      operating decisions
Virtual Technology Licensing,         Scott     A.     Haire     is    the  Series of funds advanced                   8,497
LLC a Nevada Limited Liability        Manager/Member   of  this   company,  for working capital
Company                               controls both entities financing and  purposes
                                      operating decisions
Nevada   Multicare,   LLC  a          Scott     A.     Haire     is    the  Series of funds advanced                 (13,655)
Nevada Limited Liability              Manager/Member   of  this   company,  for working capital
Company                               controls both entities financing and  purposes
                                      operating decisions
                                                                                                        --------------------
                                                                                                        $              9,538
                                                                                                        ====================
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Form 10QSB for Quarter Ended March 31, 2005
-------------------------------------------

6. We see that you pay $75,000 per year as an option fee to maintain your rights
to purchase  certain  property and you  capitalize the amount as an other asset.
Please tell us why you believe generally accepted  accounting  principles permit
you to capitalize  these payments rather than expense them.  Please support your
assertions with references to the authoritative  accounting  guidance upon which
you relied. We may have additional comments after reviewing your response.

Response:  We capitalized  the option fee because it provides a future  economic
benefit, i.e. the right to purchase the patent and related intellectual property
as  described  in the option  agreement  for one year and expiring on August 31,
2005, at which time another $75,000 option fee is due and payable or we lose our
exclusivity  rights.  From an accounting  perspective,  each year the prior year
option  fee  will  be  expensed  and  the  current  period  option  fee  will be
capitalized. Similarly, when an event occurs that destroys the future benefit or
removes our ability to obtain it, the asset will be  expensed.  As  disclosed in
our 2005 second  quarter Form 10-QSB,  the company lost its exclusive  option to

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distribute  the product due to a default under the agreement,  and  accordingly,
the option fee was expensed at that time (April 2005).

Our accounting was based on FASB Concepts Statement No. 6 "Elements of Financial
Statements a replacement  of FASB Concepts  Statement  No. 3  (incorporating  an
amendment of FASB Concepts Statement No. 2.", as defined by:

(i)  paragraph  26 - "An  asset  has  three  essential  characteristics:  (a) it
embodies a probable  future  benefit  that  involves  a  capacity,  singly or in
combination  with other assets,  to contribute  directly or indirectly to future
net cash  inflows,  (b) a  particular  entity can obtain the benefit and control
others' access to it, and (c) the  transaction or other event giving rise to the
entity's right to or control of the benefit has already occurred."

(ii) paragraph 33 - "Once acquired, an asset continues as an asset of the entity
until the entity collects it, transfers it to another entity,  or uses it up, or
some other  event or  circumstance  destroys  the future  benefit or removes the
entity's ability to obtain it."

As requested, we acknowledge the following:

     o    the company is  responsible  for the adequacy of the disclosure in the
          filing;
     o    the staff  comments  or charges to  disclosure  in  response  to staff
          comments do not foreclose the  Commission  from taking any action with
          respect to the filing; and
     o    the  company  may  not  assert  staff  comments  as a  defense  in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

Please let us know if you have further comments or need additional clarification
on any of the responses provided.

Sincerely,

/s/ Scott A. Haire

Scott A. Haire, President

SAH/ljs
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