SecProbe.io

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      Mail Stop 4561

      October 12, 2005

      VIA USMAIL and FAX (972) 250-0934

Mr. Gary W. Boyd
Vice President - Finance and Chief Financial Officer
Ascendant Solutions, Inc.
16250 Dallas Parkway, Suite 102
Dallas, Texas 75248

      Re:	Ascendant Solutions, Inc.
      Form 10-K for the year ended 12/31/2004
      Filed 3/29/2005
      Form 10-Q for the period ended 3/31/2005
      Filed 5/12/2005
      	File No. 000-27945

Dear Mr. Gary W. Boyd:

      We have reviewed your response letter dated July 8, 2005 and
have the following additional comments.  Where indicated, we think
you should revise your document[s] in response to these comments.
If you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is unnecessary.  Provide
to
us the information requested if indicated and please be as
detailed
as necessary in your explanation.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

Financial Statements and Notes

Note 1 - Organization and Significant Accounting Policies

Significant Accounting Policies

Basis of Presentation, page 46

1. Your response to our prior comment one does not address
directly
or completely our request for additional information.  Please
explain
to us in sufficient details how your definition of significant
influence over operations, as used in your consolidation policy,
complies with the consolidation guidance in GAAP. Please refer us
to
the GAAP literature that supports your consolidation policy.

2. With respect to your consolidation of Fairways Frisco, please
explain to us your basis for relying on the SFAS 94`s guidance
rather
than the SOP 78-9`s.

Fairways Frisco Partnerships, pages 54 - 56

3. We have read and considered your response to our previous
comment
two.   As stated in your response to comment one, "The Company did
not consolidate the Frisco Square Partnerships based on its
analysis
of the requirements of FIN 46 (R) at December 31, 2004."   Given
that
the Company owned 100% of Fairways Frisco and in accordance with
the
master agreement, Fairways Frisco agreed to make additional
capital
contributions to be used to pay operating expenses, tell us how
you
considered paragraph 5 of FIN 46 (R) in determining not to
consolidate the Frisco Square Partnerships at December 31, 2004.

4. We note your response to comment three and will monitor your
amendment to the Form 10-K for compliance.

FORM 10-Q OR THE QUARTER ENDED MARCH 31, 2005

Note 2 - Description of Business

Significant Accounting Policies

Investments in Limited Partnerships, page 6

5. We have read and considered your response to our previous
comment
five relating to your investment in limited partnerships accounted
for under the cost method.   Given that your investment ownership
is
more than 3 to 5%, please revise the financial statements to
account
for your limited partnership interest under the equity method as
required by EITF Topic D-46 and SOP 78-9.

*  *  *  *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your amendment that keys your
responses to our comments and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

	You may contact Wilson K. Lee, at (202) 551-3468 or me, at
(202)
551-3414 if you have questions.

						Sincerely,

Jorge Bonilla
Senior Staff Accountant

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Gary W. Boyd
Ascendant Solutions, Inc.
October 12, 2005
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