SecProbe.io

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Room 4561
						September 8, 2005

Mr. Kim Mayyasi
Chief Executive Officer and President
Gensym Corporation
52 Second Avenue
Burlington, MA 01803

Re:	Gensym Corporation
	Form 10-K for Fiscal Year Ended December 31, 2004
	Filed March 31, 2005
      Form 10-Q for Fiscal Quarter Ended June 30, 2005
	Filed August 11, 2005
	File No. 000-27696

Dear Mr. Mayyasi:

      We have reviewed the above referenced filings and have the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  We may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for Fiscal Year Ended December 31, 2004

Notes to Consolidated Financial Statements

Note 1.  Operations and Significant Accounting Policies

Revenue Recognition, page 36

1. We note that you provide certain consulting services on a
fixed-
price basis and revenues are recognized using the percentage-of-
completion method.  Tell us specifically the types of services
being
provided.  Note that recognizing revenue pursuant to SOP 81-1 is
not
permitted for service arrangements.

Form 10-Q for Fiscal Quarter Ended June 30, 2005

Item 4.  Controls and Procedures, page 30

2. We note that your previous auditors identified several material
weaknesses that existed as of December 31, 2003 and that your
current
auditors identified additional material weaknesses that existed as
of
December 31, 2004.  We further note that your controls and
procedures
were ineffective as of June 30, 2005 as a result of these material
weaknesses.  Please explain to us which, if any, of these material
weaknesses have been remediated by your corrective actions
completed
as of June 30, 2005.  In addition, please describe the corrective
actions you plan to take in addressing each material weakness that
continued to exist as of June 30, 2005 and provide us with your
expected timeline.

3. Your disclosures do not appear to indicate whether the
corrective
actions taken during the quarter ended June 30, 2005 materially
affected, or are reasonably likely to materially affect, your
internal control over financial reporting.  Please tell us how you
considered the requirements of Item 308(c) of Regulation S-K.

4. Please describe the "additional procedures" that you performed
that served as the basis for your belief that the control
weaknesses
and deficiencies did not lead to any material misstatements in the
consolidated financial statements. In addition, describe to us any
adjustments that were made to your financial statements prior to
filing that resulted from these additional procedures.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Christine Davis, Staff Accountant, at (202)
551-
3408, Mark Kronforst, Senior Staff Accountant at (202) 551-3451 or
me
at (202) 551-3489 if you have questions regarding these comments.

Sincerely,

      Brad Skinner
							Accounting Branch Chief
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Mr. Kim Mayyasi
Gensym Corporation
September 8, 2005
Page 3

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