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      Response to SEC Comment Letter of June 27, 2005

        Ascendant
          Solutions, Inc.

        16250
          Dallas Parkway, Suite 205

        Dallas,
          Texas 75248

        July
          8,
          2005

        Mr.
          Jorge
          Bonilla

        Mr.
          Wilson K. Lee

        Division
          of Corporation Finance

        United
          States Securities and Exchange Commission

        100
          F
          Street N.E.

        Washington,
          D.C. 20549

                    Re:

                    Ascendant
                      Solutions, Inc.

                    Form
                      10-K for the year ended 12/31/2004 (“Original Form 10-K”)

                    Filed
                      3/29/2005

                    Form
                      10-Q for the period ended 3/31/2005 (“Form 10-Q”)

                    Filed
                      5/12/2005

                    File
                      Nos. 0-27945

        Dear
          Messrs. Bonilla and Lee:

        This
          letter sets forth responses of Ascendant Solutions, Inc. (the “Company”) to the
          comment letter dated June 27, 2005 from the staff of the Securities and
          Exchange
          Commission (the “Commission”). Please note that the following responses are
          keyed to coincide with your comment letter.

        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.
          Response: In determining whether the Company has significant influence
          over
          operations for purposes of applying its consolidation policy, management
          of the
          Company considers its participation in the following operating activities:
          day
          to day business affairs and operating decisions of the investee, financing
          decisions, participation on the board of directors or other management
          committees, acquisition or sale of assets, approval or other consent rights
          with
          respect to investee activities and guarantees of the investee’s debt. As is
          general practice for disclosure of consolidation policies by other public
          companies, the Company does not separately disclose detailed considerations
          in
          determining “significant influence”, as these factors may differ from
          transaction to transaction depending on specific circumstances.

              Jorge
                Bonilla

              Wilson
                K.
                Lee

              July
                8,
                2005

              Page
                2

        The
          Company consolidated Fairways Frisco, L.P. (Fairways Frisco) on December
          31,
          2004 because it owned 100% of the limited partnership interests on that
          date.
          The Company made its investment of $ 154,000 in Fairways Frisco on December
          31,
          2004. The table on pages 45-46 of the Form 10-K is intended to show that
          Fairways Frisco holds a 50% interest in the Frisco Square Partnerships,
          as
          further discussed in Note 2 on pages 54-56 of the Form 10-K. The Company’s
          decision to consolidate Fairways Frisco on December 31, 2004 was based
          on its
          100% ownership of the Fairways Frisco limited partnership interests and
          the
          guidance provided in SFAS
          94, Consolidation of All Majority-Owned Subsidiaries, paragraph
          2
          which
          sets forth the general rule of consolidation policy as:

        “the
          usual condition for a controlling financial interest is ownership of a
          majority
          voting interest, and, therefore, as a general rule ownership by one company,
          directly or indirectly, of over fifty percent of the outstanding voting
          shares
          of another company is a condition pointing toward
          consolidation.”

        The
          Company did not consolidate the Frisco Square Partnerships based on its
          analysis
          of the requirements of FIN 46 (R) at December 31, 2004.

        Fairways
          Frisco Partnerships, pages 54-56

        2.
          Response: As discussed in the response to Question #1 above, the Company
          owned
          100% of the Fairways Frisco interests at December 31, 2004. As a result,
          the
          provisions of paragraph 5 of FIN 46(R) were not applicable.

        However,
          the Company did consider the provisions of paragraph
          5 of FIN 46 (R), Consolidation of Variable Interest Entities,
          in
          preparing its March 31, 2005 financial statements filed on Form 10-Q since
          it no
          longer owned 100% of the limited partnership interests of Fairways Frisco.
          Among
          the considerations were the following:

                  1)

                  The
                    equity holders participate pro-rata with their limited partnership
                    interests in the income and losses of Fairways Frisco;

                  2)

                  All
                    of the limited partners voting rights are pro-rata with their
                    equity
                    interests;

                  3)

                  The
                    equity investment at risk is sufficient for Fairways Frisco to
                    carry out
                    its business activities; and

                  4)

                  The
                    Company is not obligated to make any further capital contributions
                    to
                    Fairways Frisco and it does not guarantee any of the debt obligations
                    of
                    Fairways Frisco or any of the related Frisco Square Partnerships.

        Considering
          these factors and the fact that other participants guarantee debt, Fairways
          Frisco is not considered a variable interest entity under paragraph
          5 of FIN 46 (R). If
          Fairways Frisco was determined to be a variable interest entity, the Company
          would not absorb a majority of the entity’s losses or receive a majority of
          expected residual returns, or both, and thus per paragraph
          14 of FIN 46 (R),
          would
          not consolidate Fairways Frisco. Based on these considerations, the Company
          determined that it was not required to consolidate Fairways Frisco at March
          31,
          2005 under the provisions of FIN
          46 (R).

        3.
          Response: The information presented in the table on page 56 is correctly
          dated
          as of March 21, 2005. The Company intends to file Amendment No. 1 to Form
          10-K
          for the year ended 12/31/04 on Form 10-K/A reflecting a revised date on
          the
          accountants’ opinion.

        Note
          9
          - Investment In Limited Partnerships

        4.
          Response: The Company’s investment income for the year ended December 31, 2004
          is primarily derived from its interests in Fairways 03 New Jersey, L.P.,
          Ampco
          Partners, Ltd. and Fairways 36864, L.P. The Company does not consider any
          of
          these entities to be material to its overall financial position or results
          of
          operations for the reasons outlined below, including consideration of
Rule
          3-09 of Regulation S-X.

        The
          Company’s calculation of significant subsidiaries under Regulation
          S-X Rule 3-09
          shows
          that all three of the entities referred to in the preceding paragraph represent
          less than 10% of the first and third conditions (investment test and pretax
          income test) required to be calculated under that rule. As a result, the
          Company
          did not present separate financial statements or summarized financial
          information for these entities. Investment income for 2004, from individual
          investments and in the aggregate is less than 10% of the Company’s average
          pretax earnings for the past five years. Since the Company incurred losses
          in
          each of the past five years, except for 2004, the Company used the absolute
          values of pretax earnings, as allowed under the Interpretations
          to Rule 3-09 of Regulation S-X, and also in the SEC Accounting Disclosure
          Rules
          and Practices Official Text Topic Two (III.B.1) and Topic Two
          (I.D.1.c).
          Under
          this calculation, the Company used the absolute value of $7,656,000 as
          its
          average pretax income for purposes of the pretax income test under Rule
          3-09 of Regulation S-X.

        In
          addition to the calculations under Rule
          3-09(a),
          the
          Company considered the additional following factors in its decision to
          not
          present additional financial information:

                  1)

                  Investment
                    income was less than 1% of consolidated revenue;

                  2)

                  The
                    total assets and revenues of the individual limited partnership
                    entities
                    is less than 20% of the Company’s consolidated assets and revenues;

                  3)

                  Two
                    of the interests in limited partnerships represent limited partnership
                    investments in single tenant commercial real estate properties
                    and have no
                    substantive business operations;

                  4)

                  There
                    was no material change in the nature of the Company’s interest in these
                    entities as compared to the prior year;

                  5)

                  The
                    sole real estate property held by certain partnerships in which
                    Fairways
                    03 New Jersey, LP has its investment interest is under contract
                    to be
                    sold, and it has already received an earnest money deposit of
                    approximately 1% of the sales price. Upon completion of this
                    transaction
                    in 2005, the proceeds will be distributed to the limited partners
                    and
                    Fairways 03 New Jersey LP will have no remaining significant
                    assets or
                    future sources of income; and

                  6)

                  The
                    income from Fairways 36864, LP is due to one transaction whereby
                    a single
                    tenant commercial real estate property was developed and sold
                    and the
                    proceeds were distributed to the limited partners, leaving Fairways
                    36864
                    LP with no significant assets or future sources of income.

        The
          Company believes these additional factors support its position that providing
          additional financial information on its limited partnership investees will
          not
          provide any additional useful information for readers of the financial
          statements.

              Jorge
                Bonilla

              Wilson
                K.
                Lee

              July
                8,
                2005

              Page
                3

        Based
          on
          the results of the tests in Rule
          3-09(a),
          the
          Company did not consider its investments in these entities, either individually
          or in the aggregate, to be material to its financial position or results
          of
          operations, and thus did not provide the summarized financial information
          referred to in paragraph
          20 (d) of APB 18, The Equity Method of Accounting for Investments in Common
          Stock.

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

        Note
          2
          - Description of Business

        Significant
          Accounting Policies

        Investments
          in Limited Partnerships, page 6

        5.
          Response: In determining whether to use the cost method or the equity method
          to
          account for its investment in Fairways Frisco, the Company considered factors
          in
          addition to the percentage amount of its limited partnership interest.
          AICPA
          Statement of Position 78-9, Accounting for Investments in Real Estate Ventures
          (SOP 78-9), paragraph 8
          allows
          the cost method to be utilized for investments in limited partnerships
          where:

        “the
          investment amount is minor and the investor has virtually no influence
          over
          operating and financial policies. Such limited partner is, in substance,
          in the
          same position with respect to the investment as an investor that owns a
          minor
          common stock interest in a corporation. In such cases, the cost method
          may be
          appropriate”.

        Further,
          the Company considered the provisions of EITF
          Topic D-46, Accounting for Limited Partnership Investments,
          which
          requires all investments in limited partnerships to be accounted for in
          accordance with SOP
          78-9.
          The
          guidance in EITF
          Topic D-46
          also
          states:

        “the
          SEC staff understands that practice generally has viewed investments of
          more
          than 3 to 5 percent to be more than minor”.

        The
          Company does not consider the ownership of more than 3 to 5% to be an absolute
          requirement to use the equity method, as further discussed in the following
          paragraph.

        Based
          on
          the guidance above, the Company considered the following additional factors
          in
          determining whether to use the cost or equity method to account for its
          interest
          in Fairways Frisco:

                  1)

                  The
                    Company has no influence over the operations, property design
&
                    development, property leasing, financial policies, or any other
                    business
                    of the partnership;

                  2)

                  The
                    Company also considered that its investment is in a real estate
                    development entity that is not expected to make any distributions
                    to its
                    limited partners for the foreseeable future;

                  3)

                  The
                    Company is not obligated to make any further capital contributions
                    to
                    Fairways Frisco, nor has the Company guaranteed any of the debt
                    obligations of Fairways Frisco or the related Frisco Square Partnerships;
                    and

              Jorge
                Bonilla

              Wilson
                K.
                Lee

              July
                8,
                2005

              Page
                4

                  4)

                  The
                    Company owns less than 10% of the limited part