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[ORRICK LETTERHEAD]

October 11, 2007

Barbara C. Jacobs

Assistant Director

Securities and Exchange Commission (Mail Stop 4561)

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    PASW, Inc. (the “Company”)

    Registration Statement on Form SB-2

    Filed August 29, 2007

    File No. 333-145765

Dear Ms. Jacobs,

Please find as set forth below, our responses to the Staff’s comment letter dated September 27,
2007. For the Staff’s convenience, the Staff’s comments are set forth in italics before each
response.

General

    1.

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

    1.

    In response to the Staff’s comments, the Company has modified its disclosure throughout the
prospectus to use post-split figures for all stock information.

Cover Page

    2.

    Refer to the disclosure on page ii under the caption “About This Prospectus.” Remove or
relocate this disclosure to a section of the prospectus that is not subject to Rule 421(d).
With respect to the disclosure 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 c.f. Regulation S-B. Please ensure that the Prospectus Summary immediately follows the
Table of Contents.

    2.

    In response to the Staff’s comments, the Company has removed or relocated its disclosure
accordingly.

Forward-Looking Statements, page 14

    3.

    Refer to the statement that the prospectus includes forward looking statements “within the
meaning of” Section 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 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 stock rules are not applicable to your securities.

    3.

    The Company supplementally advises the Staff that it is seeking to list its shares of common
stock on the NASDAQ Capital Market. If the Company is not able to list its shares as planned
prior to the offering and its stock is otherwise a “penny stock” within the meaning of Rule
3a51-1 under the Securities Exchange Act of 1934, as amended, the Company will revise its
disclosure accordingly.

Liquidity and Capital Resources, page 19

    4.

    Please expand this discussion to address: (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; (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.

    4.

    In response to the Staff’s comments, the Company has modified its disclosure in the
Prospectus to indicate both its current monthly cash used to fund
operations as well as its anticipated monthly cash to be used to fund
operations.

The Company supplementally advises the Staff that it does not have
any material commitments for capital expenditures and does not
anticipate any in the future.

    5.

    Revise to state clearly whether your current 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 discussion your expected liquidity needs, please state the
extent to which you are currently using funds in your operations on a monthly basis, 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 current liabilities exceed current assets and explain how
your need to discharge current liabilities within the twelve months will impact the rate at
which you use funds in operations and your need for capital.

    5.

    In response to the Staff’s comments, the Company has modified its disclosure in the
Prospectus accordingly. The Company also supplementally advises the Staff that it pays its
expenses on a current basis and does not have outstanding current liabilities in excess of
current assets beyond the monthly cash requirements for its business as set forth in the
revised disclosure.

Selling Security Holders, page SS-3

    6.

    Please disclose any affiliations or relationships that the selling security holders have or
had with PASW, VirnetX, or any of their affiliates within the past three years.

    6.

    In response to the Staff’s comments, the Company has modified its disclosure in the
Prospectus accordingly.

    7.

    With respect to the shares to be offered for resale by all of the selling security holders
who are legal entities, please disclose 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.

    7.

    In response to the Staff’s comments, the Company has modified its disclosure in the
Prospectus accordingly.

    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 for investment banking or similar services should be identified as
underwriters.

    8.

    In response to the Staff’s comments, the Company has modified its disclosure in the
Prospectus accordingly. In addition, the Company supplementally advises the Staff that all of
the shares being registered for resale by registered broker-dealers were earned as
compensation for investment banking services.

Exhibit 5.1

    9.

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

    9.

    The Company has filed the legality opinion as Exhibit 5.1 to Amendment No. 1 to the
Registration Statement.

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 intend to rely on Rule 430B, please provide the undertaking contained in Item
512(g)(1).

    10.

    In response to the Staff’s comments, the Company has included the requested undertakings.

Please contact me at (650) 614-7455 if you have any questions or require additional information
concerning the foregoing.

    Sincerely,

    /s/ Lowell D. Ness

    cc.

    Kendal Larsen

    PASW, Inc.

    Adam J. Agron

    Brownstein Hyatt Farber Schreck, P.C.