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      SEC Comment Letter - Response dated 11-7-05

    Ascendant
      Solutions, Inc.

    16250
      Dallas Parkway, Suite 205

    Dallas,
      Texas 75248

    November
      7, 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 October 12 , 2005, from the staff of the Securities and
      Exchange Commission (the “Commission”), in response to the Company’s letter of
      July 8, 2005 which responded to the original comment letter dated June 27,
      2005
      from the Commission. Please note that the following responses are keyed to
      coincide with your October 12, 2005 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:
      The Company applies the guidance set forth in SFAS
      94
      and
SOP
      78-9
      as its
      policy in consolidating majority-owned or controlled entities. As of December
      31, 2004 and March 31, 2005, the Company owned greater than 50% of the
      outstanding stock or limited partnership interests in all of the Company’s
      consolidated subsidiaries. As such, the provisions of SFAS
      94
      and
SOP
      78-9
      for
      determining control of less than 50% owned entities was not applicable in
      determining the Company’s consolidated subsidiaries.

    2.
      Response: The Company owned 100% of the limited partnership interests of
      Fairways Frisco at December 31, 2004. In accordance with the provisions of
      SOP
      78-9,
      the
      Company consolidated Fairways Frisco at December 31, 2004 as it owned greater
      than 50% of the limited partnership interests.

        -1-

          Jorge
            Bonilla

          Wilson
            K.
            Lee

          November
            7, 2005

    Fairways
      Frisco Partnerships, pages 54-56

    3.
      Response: The Company did consider the provisions of paragraph
      5 of FIN 46 (R), Consolidation of Variable Interest Entities,
      in
      preparing its December 31, 2004 financial statements filed on Form 10-K to
      determine if the Frisco Square Partnerships were required to be consolidated.
      The considerations at December 31, 2004 included the following:

            1)

              Cole
                McDowell (the controlling member of Five Star Group) guaranteed all
                of the
                bank debt of the Frisco Square Partnerships. The outstanding bank
                debt was
                approximately $31 million at December 31, 2004. Cole McDowell was
                not
                affiliated with Fairways Frisco or the Company. Neither the Company
                nor
                Fairways Frisco (including any of its principals) had guaranteed
                any of
                the bank debt of the Frisco Square
                Partnerships

            2)

              The
                Five Star Group had a preference of $2.5 million on distributable
                cash
                flow.

            3)

              After
                the preference, the equity holders would participate pro-rata with
                their
                limited partnership interests in the income and losses of the Frisco
                Square Partnerships;

            4)

              Fairways
                Frisco’s equity commitment at risk on December 31, 2004 was approximately
                $154,000.

            5)

              The
                capital contributed to the Frisco Square Partnerships by Cole McDowell
                and/or the Five Star Group exceeded the capital contributed by Fairways
                Frisco.

    In
      accordance with paragraphs
      14-15 of FIN 46 (R),
      the
      Company determined that Cole McDowell and the Five Star Group were the primary
      beneficiary of the variable interests of the Frisco Square Partnerships at
      December 31, 2004, and thus the Frisco Square Partnerships would be consolidated
      into the Five Star Group and not into Fairways Frisco.

    4.
      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.

    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: The Company does not consider the ownership of more than 3 to 5%
      to be
      an absolute requirement to use the equity method in cases where the Company
      does
      not exercise significant influence or control over operations or financial
      policies of the limited partnership.

        -2-

          Jorge
            Bonilla

          Wilson
            K.
            Lee

          November
            7, 2005

    The
      Company notes the following SEC registrants indicate in various filings their
      ownership of greater than 5% interest in limited partnerships which are
      accounted for under the cost method:

              Registrant

              Limited
                Partnership % Owned

              Filing
                Reference

              American
                Physicians Capital, Inc

              Various

              Form
                10-K filed on 3/16/05

              Interstate
                Hotels & Resorts

              Various

              Form
                10-K filed on 3/27/03

              MDC
                Partners Inc

              Various

              Form
                10-K filed on 4/18/05

              Invacare
                Corp

              Various

              Form
                10-K filed on 3/11/05

              Harrell
                Hospitality Group Inc.

              7%

              Form
                10-KSB filed 1/20/99

    As
      noted
      in our previous response dated July 8, 2005, the Company expects its limited
      partnership interest to decline due to the addition of other third party limited
      partners that will provide the majority of the equity capital contributions
      to
      Fairways Frisco. The Company believes it is likely that its limited partnership
      interest will fall below 5% within the next 12 months as a result of the
      dilution from additional capital contributions.

    The
      Company feels that revising its financial statements to reflect the equity
      method of accounting for its investment in Fairways Frisco, only to switch
      back
      to the cost method within the next 12 months would make a complex transaction
      that much more difficult for readers of its financial statements to understand.
      Further, the administrative costs and burden to change accounting methods twice
      in a short period of time would put an unnecessary strain on the Company’s
      limited resources as a small public entity.

    Since
      its
      initial investment in Fairways Frisco, the Company has known that it would
      contribute a limited dollar amount of capital and that its ultimate position
      as
      a limited partner would be minor. The economic substance of this transaction
      supports the cost method, whereas the form of entity invested in by the Company
      is the primary suggesting factor for using the equity method.

    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

              4)

              The
                Company owns less than 10% of the limited partnership interests of
                the
                Frisco Square Partnerships (indirectly through Fairways Frisco).
                The
                Frisco Square Partnerships are the entities that own the real estate
                assets being developed and managed by the general partner (in which
                the
                Company has no ownership interest) of Fairways Frisco.

        -3-

          Jorge
            Bonilla

          Wilson
            K.
            Lee

          November
            7, 2005

    Additionally,
      the Company hereby makes the following representations and
      acknowledgements:

    A. The
      Company represents that it is responsible for the adequacy and accuracy of
      the
      disclosure in its Form 10-K Filings and Form 10-Q Filings;

    B. The
      Company acknowledges that staff comments or changes to disclosure in response
      to
      staff comments do not foreclose the Commission from taking any action with
      respect to the Form 10-K Filings and Form 10-Q Filings; and

    C. The
      Company acknowledges that it 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.

    Please
      contact me with any additional information requests or further comments with
      respect to the 10-K Filings and Form 10-Q that you might have.

    Sincerely
      yours,

    Ascendant
      Solutions, Inc.

              By:

              /s/
                Gary W. Boyd

              Gary
                W. Boyd

              Vice
                President-Finance and Chief Financial Officer

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