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Acceleration Request Letter

February
14, 2005

Securities
and Exchange Commission

Judiciary
Plaza

450 Fifth
Street N.W.

Washington,
D.C. 20549

      Re:

      Smart
      Online, Inc.

      Registration
      Statement on Form SB-2

      File
      No.: 333-119385

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of
1933, as amended, Smart Online, Inc. hereby requests that the effective date of
the above-captioned Registration Statement be accelerated so that the
Registration Statement may become effective at 5:00 p.m. on February 14, 2005,
or as soon thereafter as possible.

Smart
Online, Inc. hereby acknowledges 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 respect to the filing;

    §

      the
      action of the Commission or the staff, acting pursuant to delegated
      authority, in declaring the filing effective, does not relieve the company
      from its full responsibility for the adequacy and accuracy of the
      disclosure in the filing; and

    §

      the
      company may not assert this action as a defense in any proceeding
      initiated by the Commission or any person under the federal securities
      laws of the United States

      SMART
      ONLINE, INC.

    /s/
      Michael Nouri

      Michael
      Nouri, President

cc:
James
Verdonik, Esq.