SecProbe.io

September 27, 2007  Mail Stop 4561  Kendall Larsen Chief Executive Officer VirnetX, Inc. 5615 Scotts Valley Drive, Suite 110 Scotts Valley, CA 95066
RE: PASW, Inc.
  Registration Statement on Form SB-2
Filed August 29, 2007
  File number 333-145765
Dear Mr. Larsen:

We have limited our review of your filing to those issues we have addressed in
our comments.  We think you should revi se your document 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.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

General

1. In order to minimize possible confusion, plea se be consistent in  using either pre-
split or post-split figures for all stock information used in the prospectus.

Cover Page

2. Refer to the disclosure on page ii unde r the caption “About This Prospectus.”

Kendall Larsen
PASW, Inc.
September 27, 2007 Page 2 of 5
Remove or relocate this disclosure to a s ection of the prospectus  that is not subject
to Rule 421(d).  With respect to the di sclosure in the second full paragraph, you
should advise dealers of their prospectus  delivery obligation on the outside back
cover page in accordance with Item 502 of Regulation S-B.  Please ensure that the
Prospectus Summary imme diately follows the Table of Contents.
  Forward-Looking Statements, page 14

3. Refer to the statement that the prospe ctus includes forward looking statements
“within the meaning of” Sec tion 27A of the Securities Act and Section 21E of the
Securities Exchange Act of 1934.  Please be  advised that Section 27A(b)(1)(C) of
the Securities Act and Section 21E(b)( 1)(C) of the Securities Exchange Act
expressly state that the safe harbor for forward looking statements does not apply to statements made by companies that issue penny stock.  Also, as appropriate, revise the disclosure contained in the second full risk factor on page 12, which
indicates that you believe the penny stoc k rules are not ap plicable to your
securities.

Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 16

Liquidity and Capital Resources, page 19

4. Please expand this discussion to addre ss: (i) any known trends, events or
uncertainties that have or are reasonably likely to have a material impact on your
short-term or long-term liquidity; (ii) in ternal and external sources of liquidity;
(iii) any material commitments for capital expenditures and the expected sources
of funds for such expenditures.  Refer to  Items 303(b)(i)-(iii) of Regulation S-B.
5. Revise to state clearly whether your cu rrent and available capital resources are
sufficient to fund planned operations for a period of not less than twelve months
from the date of the prospectus.  To the extent you do not have sufficient
resources to fund planned operations for the 12-month period, state the estimated
deficiency in dollar terms and discuss how you plan to address the deficiency.  In
discussing your expected liquidity needs, please state the extent to which you are
currently using funds in your operations on a monthly basi s, and indicate whether
the expected rate at which capital is used in operations over the 12 month period
will vary from that amount, by how much and why.  In preparing this disclosure, consider the extent to which your curren t liabilities exceed current assets and
explain how your need to discharge current liabilities within the twelve months

Kendall Larsen
PASW, Inc.
September 27, 2007 Page 3 of 5
will impact the rate at which you use funds in operations and your need for capital.
  Selling Security Holders, page SS-3

6. Please disclose any affiliati ons or relationships that th e selling security holders
have or had with PASW, VirnetX, or any of their affiliates within the past three
years.
7. With respect to the shares to be offered for resale by all of the selling security
holders who are legal entities, please disc lose the individual or individuals who
exercise the voting and dispositive powers .  Refer to Interp. I.60 of Telephone
Interp. Manual (July 1997) and Interp.4S  of Reg. S-K section of 3/99 Supp. to
Manual.
8. Tell us whether any of the selling security holders are registered broker-dealers or affiliates of registered broker-dealers.  Be advised that all selling security holders who are registered broker-dealers or affiliates of broker-dealers who did not receive their securities as compensation fo r investment banking or similar services
should be identified as underwriters.
  Exhibit 5.1

9. We will review the legality opinion upon filing and, if appropriate, we may issue comments on its substance.

Undertakings, page II-4

10. Please provide the undertakings required by Item 512(g) of Regulation S-B, as
applicable.  If you intend to rely on Rule 430C, please provide the undertaking
contained in Item 512(g)(2).  If you in tend to rely on Rule 430B, please provide
the undertaking contained in Item 512(g)(1).

As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to
expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.

Kendall Larsen
PASW, Inc.
September 27, 2007 Page 4 of 5
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Act of 1933 and that they have  provided all information investors require
for an informed investment decision.  Since the company and its management are in  possession of all facts relating to a company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
Notwithstanding our comments, in the even t the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:
• should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from
taking any action with re spect to the filing;

• the action of the Commission or the st aff, acting pursuant to delegated
authority, in declaring the filing eff ective, does not re lieve the company
from its full responsibility for the ade quacy and accuracy of the disclosure
in the filing; and

• the company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal secu rities laws of the United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.
We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.

Kendall Larsen
PASW, Inc. September 27, 2007 Page 5 of 5
Please contact Hugh Fuller at (202) 551- 3853 or Jay Ingram at (202) 551-3397 if
you have any questions.  If you require further assistance please contact me at (202) 551-
3730

     S i n c e r e l y ,         Barbara C. Jacobs      A s s i s t a n t  D i r e c t o r
  CC: Lowell D. Ness  Orrick, Herrington & Sutcliffe LLP  1000 Marsh Road  Menlo Park, CA 94025  Facsimile number: (650) 614-7401   Adam J. Agron  Brownstein Hyatt Farber Schreck, P.C.  410 17
th Street, Suite 2200
 Denver, CO 80202  Facsimile number: (303) 223-0934