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CORRESP
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corresp

Zix Corporation

2711 North Haskell Avenue, Suite 2200, LB 36

Dallas, Texas 75204-2960

October 27, 2005

VIA EDGAR AND FACSIMILE (202) 772-9210

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

    Daniel Lee

Division of Corporation Finance

    Re:

    Zix Corporation

    Registration Statement on Form S-3

    File No. 333-128186

Ladies and Gentlemen:

     Pursuant to Rule 461 of the rules and regulations promulgated under the Securities Act of
1933, as amended, Zix Corporation (the “Company”) hereby requests that the Securities and Exchange
Commission (the “Commission”) take appropriate action to accelerate the effectiveness of the
above-referenced Registration Statement on Form S-3 so that it becomes effective at 5:30 p.m.,
Washington D.C. time, on Thursday, October 27, 2005, or as soon as practicable thereafter.

     The Company hereby acknowledges that (i) 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; (ii) 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 (iii) 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.

     Please address any questions or comments with respect to this request to our counsel, Baker
Botts L.L.P., as follows: Sarah Rechter, Baker Botts L.L.P., 2001 Ross Avenue, Dallas, Texas 75201
(ph: 214/953-6419; fax: 214/661-4419).

    Very truly yours,

Zix Corporation

    By:
    /s/ Ronald A. Woessner

    Name:

    Ronald A. Woessner

    Title:

    S.V.P. and General Counsel