SecProbe.io

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                                                        THELEN REID & PRIEST LLP
                                                                Attorneys at Law
                                                        ------------------------

                                                                875 Third Avenue
                                                         New York, NY 10022-6225

                                                               Tel. 212.603.2000
                                                               Fax  212.603.2001

                                                              www.thelenreid.com

                                  July 27, 2005

Division of Corporation Finance
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Attention:   Mr. Mark P. Shuman

      RE:   ARTEMIS INTERNATIONAL SOLUTIONS CORPORATION
            POST-EFFECTIVE AMENDMENT NO. 1 TO FORM S-1
            FILE NO. 333-117486

            FORM 10-K FOR THE YEAR ENDED DECEMBER 31,2004
            FORM 10-Q FOR THE QUARTER ENDED MARCH 31, 2005
            FILE NO. 0-29793

Ladies and Gentlemen:

     Transmitted herewith is the response of Artemis International Solutions
Corporation (the "Company") to the comments made in your letter dated July 19,
2005 to Robert S. Stefanovich, CFO of the Company. Your comments and the
Company's response are set forth below.

Form 10-K for the year ended December 31, 2004
----------------------------------------------

Item 9A. Controls and Procedures
--------------------------------

     1.   You state that an internal control system "can provide only
          reasonable, not absolute, assurance that the objectives of the control
          system are met." In your response letter, tell us whether your
          disclosure controls and procedures are designed to provide reasonable
          assurance of achieving their objectives and whether your chief
          executive officer and chief financial officer concluded that your

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July 27, 2005
Page 2

          disclosure controls and procedures are effective at that reasonable
          assurance level. Please refer to Section II.F.4 of Release No. 33-8238
          for additional guidance.

     RESPONSE:

     The Company has confirmed that its disclosure controls and procedures are
     designed to provide reasonable assurance of achieving their objectives. The
     Company has also confirmed that the chief executive officer and chief
     financial officer have concluded the Company's disclosure controls and
     procedures are effective at that reasonable assurance level.

     2.   We note that you evaluated the effectiveness of your disclosure
          controls and procedures as of a date within 90 days prior to the
          filing of your report. The evaluation of your disclosure controls and
          procedures pursuant to Rule 13a-15(b) under the Exchange Act is to be
          made as of the end of each fiscal quarter. Please advise us whether
          your disclosure controls and procedures were effective as of December
          31, 2004 and, with respect to your subsequent periodic filing, March
          31, 2005.

     RESPONSE:

     The Company has confirmed that its disclosure controls and procedures were
     effective as of December 31, 2004 and with respect to the subsequent
     periodic filing as of March 31, 2005.

     3.   Your disclosure with respect to any changes in your internal control
          over financial reporting does not meet the requirements of Item 308(c)
          of Regulation S-K. For example, your disclosure states that "there
          were no significant changes made in [y]our internal controls over
          financial reporting." Item 308 requires the disclosure of any change
          that occurred during the quarter that has materially affected, or is
          reasonably likely to materially affect, your internal control. Please
          confirm that for the quarter ended December 31, 2004 there were no
          changes in your internal control over financial reporting that
          occurred during the quarter that materially affected, or were
          reasonably likely to materially affect, your internal, control over
          financial reporting. This comment also applies to your subsequent
          periodic filing. Please see Item 308(c) and Release No. 33-8238 for
          additional guidance.

     RESPONSE:

     The Company has confirmed that for the quarters ended December 31, 2004 and
     March 31, 2005, there were no changes in its internal control over
     financial reporting that occurred during the respective quarters that
     materially affected, or were reasonably likely to materially affect the
     Company's internal control over financial reporting.

     4.   Please confirm that you will note the foregoing comments when
          preparing your periodic filings.

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July 27, 2005
Page 3

     RESPONSE:

     The Company has confirmed that it will note the foregoing comments when
preparing its periodic filings.

                                            THELEN REID & PRIEST LLP
                                            Counsel for Artemis International
                                            Solutions Corporation

                                            By:/s/ Harvey K. Newkirk
                                            ------------------------------------
                                                   Harvey K. Newkirk, Esq.

cc: Robert S. Stefanovich
    Charles Savoni, Esq.
    Artemis International Solutions Corporation

    Robert S. Matlin, Esq.
    Thelen Reid & Priest LLP
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