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Sidley Austin Brown & Wood llp

BEIJING

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BRUSSELS

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CHICAGO

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DALLAS

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GENEVA

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HONG KONG

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LONDON

WRITER’S DIRECT NUMBER

(312) 853-7454

Bank One Plaza

10 S. Dearborn Street

Chicago, Illinois 60603

Telephone 312 853 7000

Facsimile 312 853 7036

www.sidley.com

Founded 1866

LOS ANGELES

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NEW YORK

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SAN FRANCISCO

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SHANGHAI

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SINGAPORE

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TOKYO

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WASHINGTON, D.C.

WRITER’S E-MAIL ADDRESS

johare@sidley.com

August 26, 2005

VIA EDGAR SUBMISSION

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Maryse Mills-Apenteng

    Re:

    Technology Solutions Company

Preliminary Proxy Statement on Schedule 14A filed on August 19, 2005

Form 10-K for the year ended December 31, 2004

File No. 0-19433

Ladies and Gentlemen:

     On behalf of Technology Solutions Company (“TSC” or the “Company”), we are writing in response
to the comments contained in the staff’s comment letter dated August 24, 2005 (the “Comment
Letter”) with respect to TSC’s Preliminary Proxy Statement on Schedule 14A filed on August 19, 2005
(as amended and supplemented, the “Proxy Statement”) and TSC’s Annual Report on Form 10-K for the
year ended December 31, 2004, filed on March 24, 2005 (the “10-K”). The Company will incorporate
the amendments described herein in a definitive proxy statement that it intends to file on or about
September 15, 2005. For the convenience of the staff, we have set forth the comments contained in
the Comment Letter along with the responses of TSC.

Reverse Stock Split

    1.

    Please revise to state whether the reverse stock split is part of a “Rule 13e-3 transaction”
as defined in paragraph (a)(3) of that regulation and briefly summarize the basis for your
conclusion. Please note that this term encompasses any series of transactions involving one
or more transactions described in paragraph (a)(3)(i) of the rule. In this regard, we note
from your disclosure in the Form 10-K for the period ended December 31, 2004 that there were
387 holders of record of your common stock as of March 11, 2005. Your disclosure should
include the number of record holders both before and after the reverse stock split.

SIDLEY AUSTIN BROWN & WOOD LLP IS A LIMITED LIABILITY PARTNERSHIP

PRACTICING IN AFFILIATION WITH OTHER SIDLEY AUSTIN BROWN & WOOD PARTNERSHIPS

    Sidley Austin Brown & Wood llp

    Chicago

Securities and Exchange Commission

August 26, 2005

Page 2

    RESPONSE: In response to the staff’s comment, the Company confirms that the proposed
reverse stock split is not a Rule 13e-3 transaction. Although it would be a reverse stock
split of a class of equity securities involving the purchase of fractional interests within
the scope of Rule 13e-3(a)(3)(i)(c), it is not expected to cause the securities to be held
of record by less than 300 persons and in fact one of the intended purposes of the reverse
stock split is to maintain the Company’s listing on The Nasdaq National Market. The Company
also confirms that it will disclose in the Proxy Statement that, if the reverse stock split
is implemented, there will be more than 300 holders of record of the Company’s common stock
both before and after the reverse stock split.

    2.

    We call your attention to Rule 10b-17, which you should consult in connection with the
process of implementing any stock split.

    RESPONSE: The Company acknowledges Rule 10b-17 and the requirements set forth therein with
respect to notice of the reverse stock split. In accordance with Rule 10b-17(b)(3) and the
rules of The Nasdaq National Market, and subject to approval of the reverse stock split by
the Company’s stockholders, the Company will provide notice of the reverse stock split to
Nasdaq not less than 10 calendar days prior to the effective date of the reverse stock
split.

Information required by Part III of Form 10-K

    3.

    It appears that you have not held an annual meeting to conduct an election of directors and
have not filed the information required by Part III of your Form 10-K for the period ended
December 31, 2004 within 120 days after the end of the fiscal year. Please tell us when you
intended to file this information and provide us with your analysis regarding whether you are
in compliance with state law requirements governing annual meetings. In this regard, please
tell when you held your last annual meeting and cite relevant state statutes that govern the
frequency and obligation to hold annual meetings. In addition, please tell us what your
articles of incorporation and bylaws specify as to the frequency with which annual meetings
are to be held. We may have further comment.

    RESPONSE: Pursuant to a telephone conversation with the staff on August 25, 2005, the
Company understands that this comment has been withdrawn.

    In addition, the Company acknowledges as follows:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in the
Proxy Statement and the 10-K;

    •

    staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the Proxy Statement and
the 10-K; and

    Sidley Austin Brown & Wood llp

    Chicago

Securities and Exchange Commission

August 26, 2005

Page 3

    •

    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.

* * * * *

     If you have any questions regarding the foregoing, please contact the undersigned at (312)
853-7454 or Philip J. Downey, Vice President – General Counsel & Corporate Secretary of the
Company, at (312) 228-4647.

    Very truly yours,

    /s/ John M. O’Hare

    John M. O’Hare

cc: Philip J. Downey