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      SEC Comment Letter Response - December 2, 2005

    Ascendant
      Solutions, Inc.

    16250
      Dallas Parkway, Suite 205

    Dallas,
      TX 75248

      December
        2, 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 November 16, 2005, from the staff of the Securities
        and
        Exchange Commission (the “Commission), in response to the Company’s comment
        response letter dated November 7, 2005. Please note that the following responses
        are keyed to coincide with your November 16, 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 owned 100% of the limited partnership interests of Fairways Frisco
        at December 31, 2004. The Company made its investment of $154,000 in Fairways
        Frisco on December 31, 2004 at approximately 5:00 pm because it was the only
        limited partner in town at the time of the closing. In accordance with the
        provisions of SOP
        78-9,
        paragraph
        10,
        the
        Company consolidated Fairways Frisco at December 31, 2004 as it owned greater
        than 50% of the limited partnership interests. The Fairways Frisco limited
        partnership agreement provides that major decisions must be approved by a
        majority of the limited partners. These major decisions, as further defined
        in
        the partnership agreement, include the important rights set forth in paragraph
        9
        of SOP
        78-9,
        with
        the exception of the right to replace the general partner (other than for
        cause). Therefore, as the only limited partner at the close of business on
        December 31, 2004, the Company was deemed to have the controlling interest
        in
        the limited partnership.

      In
        January of 2005, other limited partners contributed capital to Fairways Frisco
        and the Company ceased to be the controlling limited partner since it no
        longer
        had the sole decision authority for the major decisions in the limited
        partnership agreement.

          -1-

          Jorge
            Bonilla

          Wilson
            K.
            Lee

          December
            2, 2005

      Additionally,
        the Company consolidates CRESA Partners of Orange Co., L.P. as it owns 99%
        of
        the limited partnership interests and because it has approval rights over
        certain “major decisions”, as further defined in the partnership agreement,
        including, but not limited to the important rights set forth in paragraph
        9 of
SOP
        78-9,
        with
        the exception of the right to replace the general partner (other than for
        cause).

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

      Note
        2
        - Description of Business

      Significant
        Accounting Policies

      Investments
        in Limited Partnerships, page 6

      3.
        Response: The Company continues to believe that it is appropriate to use
        the
        cost method of accounting for the following reasons:

              a.

                The
                  Company currently owns approximately 12.6% of the limited partnership
                  interests of Fairways Frisco, and this percentage is continuing
                  to decline
                  as additional capital is contributed to the partnership by parties
                  other
                  than the Company in order to fund
                  development.

              b.

                Multiple
                  buildings are planned to be started by Fairways Frisco in the next
                  6
                  months, resulting in additional capital calls by Fairways Frisco
                  of over
                  $20 million. This would bring the total partnership capital of
                  Fairways
                  Frisco to over $30 million. The Company intends to fund none of
                  these
                  capital calls. As a result, the Company’s interest in Fairways Frisco is
                  expected to be less than 4%.

              c.

                Discussions
                  with institutional investors are ongoing for a capital infusion
                  in excess
                  of $20 mm for 2006 and beyond.

              d.

                Once
                  the Company’s interest is below 5%, it will be required under the
                  provisions of SFAS 154 to restate its financial statements back
                  to the
                  cost method. (i.e. return them to how they are now
                  stated)

              e.

                The
                  equity method of accounting will not result in a more accurate
                  reflection
                  of the company’s economic interest in Fairways Frisco, as the Company is
                  not required to fund any operating losses or debts of Fairways
                  Frisco.
                  There is no impairment of the Company’s recorded investment in Fairways
                  Frisco, and the Company does not believe that recording this investment
                  under the cost method is a misstatement of its financial
                  statements.

              f.

                The
                  Company is not obligated to fund any capital requirements, including
                  any
                  accumulated operating losses, for Fairways Frisco. The Company
                  does not
                  have any current plans to make additional capital contributions
                  to
                  Fairways Frisco.

              g.

                A
                  complicated history of 10-K, 10-Q and 8-K disclosures (including
                  amendments to implement the equity method) will become more confusing
                  to
                  readers if the Company is required to switch from the cost method
                  to the
                  equity method and then back to the cost method within a short period
                  of
                  time. The Company does not believe that multiple restatements of
                  its
                  financial statements which ultimately results in the use of the
                  cost
                  method (as is currently used) would be in the best interest of
                  readers of
                  the Company’s financial statements.

              h.

                No
                  limited partner distributions are expected for the foreseeable
                  future

              i.

                Restating
                  multiple quarters of financial statements places a significant
                  administrative and expense burden on small public company
                  resources.

              j.

                EITF
                  Topic D-46 states that “the SEC staff understands
                  that practice generally
                  has viewed investments of greater than 3 to 5 percent to be more
                  than
                  minor.” The Company does not view this guidance as an absolute rule
                  requiring the use of the equity method in light of the factors
                  sighted
                  above and the fact that it has no influence over the operating
                  and
                  financial policies of Fairways
                  Frisco.

          -2-

            Jorge
              Bonilla

            Wilson
              K.
              Lee

            December
              2, 2005

      The
        Company expects the impact of changing the method of accounting for its
        investment in Fairways Frisco from the cost method to the equity method would
        be
        to record equity in the losses of Fairways Frisco in the range of $400,000to
        $500,000 for the nine months ended September 30, 2005. The Company would
        record
        its interest in the net losses of Fairways Frisco for each of the first three
        quarters of 2005. This would reduce the carrying amount of the Company’s
        investment in Fairways Frisco. This adjustment would have no impact on net
        working capital, nor would it have any impact on the Company’s overall
        obligations with respect to Fairways Frisco’s development activities. The
        Company’s exposure under the limited partnership agreement is limited to the
        recorded amount of its investment and it is not liable for any debts or losses
        incurred by Fairways Frisco.

      The
        Company is not opposed to disclosure going forward in its Annual Report on
        Form
        10-K and its interim reports on Form 10-Q of the operating results, financial
        position and appraised real estate values of Fairways Frisco. This disclosure
        would also inform readers that the Company has no obligation to fund any
        actual
        or expected operating losses during the early development period or any debts
        of
        Fairways Frisco. The Company believes this disclosure is preferable to multiple
        offsetting restatements of its financial statements that end up having no
        net
        impact on its retained earnings or the recorded value of its investment in
        Fairways Frisco

      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

      -3-