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CORRESP
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corresp

[LETTERHEAD OF SIDLEY AUSTIN BROWN & WOOD LLP]

September 22, 2005

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    West Corporation

    Form S-3 filed August 30, 2005

    (SEC File No. 333-127965)

Ladies and Gentlemen:

     On behalf of West Corporation (“West”), we are writing in response to the comments contained
in the Staff’s comment letter dated September 21, 2005 (the “Comment Letter”) with respect to
West’s Registration Statement on Form S-3, as filed with the Securities and Exchange Commission on
August 30, 2005 (the “Registration Statement”). For the convenience of the Staff’s review, we have
set forth the comments contained in the Staff’s Comment Letter along with the responses of West.

General

    1.

    Please file your Response Letter dated September 15, 2005 on EDGAR as a correspondence.

    Concurrently with filing this letter, we have filed our Response Letter dated September 15,
2005 on EDGAR as a correspondence.

Calculation of Registration Fee

    2.

    We do not agree that you may register for resale an indeterminate number of shares resulting
from operation of the conversion formula. Although no additional fee is required, you must
register a good-faith estimate of the maximum number of shares that you may issue upon
conversion. For additional guidance, refer to paragraph B.77 of the Division’s Telephone
Interpretations Manual and Rule 457(i).

    We have made the requested change in Footnote (1) under the caption “Calculation of
Registration Fee” on the cover page of Amendment No. 1 to the Registration Statement.

SIDLEY
AUSTIN BROWN & WOOD LLP

    CHICAGO

September 22, 2005

Page 2

     If you have any questions regarding the foregoing or the amendment to the Registration
Statement, please contact the undersigned at (312) 853-7570, Paul L. Choi at (312) 853-2145 or
Robert Mandell at (212) 839-5360.

    Very truly yours,

    /s/ Jenny L. Lauth