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                                                              August 26, 2005
Room 4561

United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, DC 20549

Attention:   Kathleen Collins, Accounting Branch Chief
              David Edgar, Staff Accountant

              Re:   Acies Corporation
                    Form 10-KSB for Fiscal Year Ended March 31, 2005
                    (File No. 000-49724)

Ladies and Gentlemen:

         The following responses address the comments of the reviewing Staff of
the Commission as set forth in the comment letter of August 15, 2005 relating to
the Annual Report on Form 10-KSB for Fiscal Year Ended March 31, 2005 of Acies
Corporation ("Acies" or the "Company"). On behalf of the Company, Acies and its
auditors respond as follows.

Note 1-Summary of Significant Accounting Policies

Revenue Recognition, page F-6

1.       We note your disclosure on page 4 that the Company is a Strategic
         Partner of Paymentech LP and a registered member service provider of JP
         Morgan Chase Bank. Describe in detail the services provided under each
         of these arrangements. Also provide your revenue recognition policy
         under each of these arrangements. If EITF 99-19 is the accounting
         literature you are applying then provide a detailed analysis of your
         consideration for each of the factors in paragraphs 7-17 of EITF 99-19
         in determining whether to account for such sales on a gross or net
         basis.

         Response:

RELATIONSHIPS WITH J.P. MORGAN CHASE BANK AND PAYMENTECH LP

         Visa and MasterCard are known as bankcard associations
("Associations"). The companies that issue credit and debit bankcards are
members of the Associations and are known in the industry as ("Issuing Banks").
Only Issuing Banks can be members of the Associations. J.P. Morgan Chase Bank is
an Issuing Bank.

<PAGE>

         Acies' customers are the merchants who need and utilize electronic
payment processing services for the purpose of being able to accept from
consumers any or all forms of non-cash payments in selling the merchants'
products and/or services ("Merchants"). There are hundreds of independent
companies across the country ("Independent Payment Service Providers") which
offer to Merchants credit and debit card processing services, including the
ability to accept credit and debit card transactions. Acies Corporation,
principally through its wholly owned subsidiary, Acies, Inc., is an Independent
Payment Service Provider. An Independent Payment Service Provider must be
authorized by an Association in order to offer Merchants these services as they
relate to the acceptance of cards issued by Issuing Banks which are members of
each Association. In order to be authorized, an Independent Payment Service
Provider must become a "Registered Member Service Provider" (in the case of
Mastercard authorization; the equivalent for Visa is "Independent Service
Organization"), which requires a relationship with an Issuing Bank that is a
member of the Association. Thus, an Issuing Bank becomes a "Sponsor Bank" for
the Registered Member Service Provider. Acies is a Registered Member Service
Provider (for Mastercard and an Independent Service Organization for Visa). J.P.
Morgan Chase Bank is our Sponsor Bank.

         Acies recognizes no revenue from J.P. Morgan Chase Bank. Acies benefits
from the relationship by having the ability to be a Registered Member Service
Provider (for Mastercard and an Independent Service Organization for Visa), and
by having a relationship with Chase Merchant Services, LLC (see below). J.P.
Morgan Chase Bank benefits from the relationship through its parental
relationship with Chase Merchant Services, LLC (see below).

         Chase Merchant Services, LLC is a joint venture between Chase Merchant
Ventures, Inc., a subsidiary of J.P. Morgan Chase Bank, and First Data Corp. All
credit and debit card transactions accepted by Merchants and enabled by
Independent Payment Service Providers (like Acies) must ultimately be processed
through a sophisticated data processing and telecommunications system
("Settlement Processing Platform").

         There exist many such Settlement Processing Platforms in the United
States, with varying degrees of capabilities as to the types of transactions
they may accept and the types of point-of-sale equipment with which they are
compatible. Acies has access to, and relationships with, several Settlement
Processing Platform providers. Acies feels that the most robust Settlement
Processing Platform, known as Omaha, is offered by First Data Corp. Acies
established and maintains a relationship and contractual agreement with Chase
Merchant Services in order to have access to, and to be able to service certain
Merchants on, the Omaha Settlement Processing Platform, as well as other
platforms offered by First Data.

         Acies recognizes no revenue from Chase Merchant Services. Acies'
service revenues are received from certain Merchants which Acies has placed on
First Data Settlement Processing Platforms as those Merchants' funds are settled
through Chase Merchant Services and its affiliates. The nature of the
relationship is such that Chase Merchant Services is a vendor to Acies. Fees
charged by Chase Merchant Services, all of which relate to the utilization of
First Data's Settlement Processing Platforms by Acies, are recognized as
expenses classified as Cost of Services.

         Paymentech, LP is also a Settlement Processing Platform provider, on
whose platforms Acies elects to service certain Merchant accounts when it may be
a better payment processing solution for those Merchants.
<PAGE>

         Acies recognizes no revenue from Paymentech, LP. Acies' service
revenues are received from certain Merchants which Acies has placed on
Paymentech, LP Settlement Processing Platforms as those Merchants' funds are
settled through Paymentech, LP and its affiliates. The nature of the
relationship is such that Paymentech, LP is a vendor to Acies. Fees charged by
Paymentech, LP, all of which relate to the utilization of its Settlement
Processing Platforms by Acies, are recognized as expenses classified as Cost of
Services.

SERVICES PERFORMED FOR MERCHANTS BY ACIES

         Acies performs the following services for Merchants, mostly related to
credit and debit card processing, electronic benefit transfer, ACH transfer,
check acceptance, and gift & loyalty card processing:

      o     Consult regarding business and processing experience

      o     Assess needs o Recommend appropriate equipment and processing
            platform

      o     Negotiate and/or set pricing (100% control)

      o     Assist in completion of application

      o     Perform preliminary underwriting

      o     Prepare contractual agreement

      o     Sign merchant to three-year agreement to provide processing services

      o     Sell or lease equipment to Merchants, where appropriate

      o     Build equipment file parameters

      o     Download / Deploy equipment

      o     Train Merchants on how to use equipment

      o     Train Merchants on how to prevent fraud

      o     Perform and/or oversee and/or provide support re: installation
            process

      o     Perform testing

      o     Quality assurance

      o     Handle on-going service issues, processing questions and software
            updates

      o     Administer all changes to the processing account

      o     Future equipment upgrades

      o     Provide ancilliary services (banking, advances, etc.)

      o     Retention

      o     Process Chargeback Requests

      o     Process/Administer Retrieval Requests

      o     Interchange Investigations

      o     Review Statements

      o     ACH Transfers

      o     Review Monetary Batches (daily, weekly, monthly)

      o     Provide supplies needed for point of sale equipment

      o     Administer Entitlements (such as: Amex, Discover, Diners, EBT,
            debit, Voyager, etc.)

      o     Risk Management o Association Compliance (Visa/Mastercard
            compliance)

      o     Control All Communications to Merchants

      o     Contract renewals and cancellations

         REVENUE RECOGNITION

         When a Merchant enters into an agreement with Acies for us to provide
electronic payment processing services, Acies owns the rights to the Merchant's
account. Acies determines which services for each account will be outsourced for
a fee paid by Acies to a variety of vendor/partners, as well as to which of a
choice of vendor/partners each of these services will be outsourced. At any
point in time, and solely at Acies' discretion, Acies may change vendor/partners
for any outsourced service.
<PAGE>

         These Merchant accounts have the characteristic of "portability." For
example, Acies may change the account's Processing Platform, or sell the account
to a competitor of Acies which may or may not utilize the same vendor/partners
as did Acies for that Merchant account. Should a Merchant end its relationship
with Acies as contractually allowed for in its agreement, the Merchant may
change to a competitor of Acies which may or may not utilize the same
vendor/partners as did Acies for that Merchant account. In addition, Acies has
the capability of purchasing Merchant accounts which are portable and Acies may
or may not utilize the same vendor/partners as did the seller of those Merchant
accounts. Acies therefore has all of the business risk associated with
maintaining the Acies/Merchant relationship, and Acies utilizes on an
account-by-account basis, at Acies sole discretion, vendor/partners to provide
any services to the Merchant.

         Acies' records the revenue which is due from the Merchant to Acies for
providing some or all of the services listed above ("Revenue"), and is therefore
is completely our revenue. This Revenue is derived from a series of formulae
which differs from Merchant to Merchant and in each case is based on Acies'
specific contractual agreement with each Merchant. All pricing of the various
charges comprising Revenue is based on rates set by Acies resulting from an
arm's length negotiation with each Merchant.

         Cost of Services includes costs which are due from and paid by Acies to
our vendor/partners, and are based on contractual agreements which Acies has for
each outsourced service for each vendor/partner. All of these components of Cost
of Services are solely based on non-Merchant-specific contractual criteria,
without any regard by these vendor/partners as to any pricing arrangements
between Acies and its Merchants.

         Based on the above, we feel that Acies is responsible for, is in
control over, has determination of, has ownership of, and has all of the
business risk relating to every Merchant account and the corresponding Revenue
stream as Acies has historically recognized, recorded and reported in its
financial statements.

         APPLICATION OF EITF 99-19

         Our analysis of considering paragraphs 7 through 17 of EITF 99-19 in
determining whether to account for our revenue on a gross or net basis is as
follows:

         Indicators of Gross Revenue Reporting

      o     Paragraph 7 - The Company is the primary obligor in the arrangement.

            Acies is responsible for providing services to the customer, the
      Merchant, including but not limited to fulfillment and the acceptability
      of all services provided.

      o     Paragraph 8 - The Company has general inventory risk.

            Not   applicable.

      o     Paragraph 9 - The Company has latitude in establishing price.

            As mentioned earlier, all pricing of the various charges
      comprising Revenue is based on rates set by Acies resulting from an
      arm's length negotiation with each Merchant. These rates have no
      bearing on the Cost of Services, and are completely under Acies'
      control and set at Acies' sole discretion.
<PAGE>

      o     Paragraph 10 - The Company changes the product or performs part of
            the service. Acies performs most of the services it sells to it
            customers, the Merchants. A list of most of the services performed
            by Acies can be found at the beginning of this letter.

      o     Paragraph 11 - The Company has discretion in supplier selection.

            Acies maintains multiple vendor/partners to supply any given service
      which it determines should be outsourced for any given Merchant account.
      For any given Merchant account, for any given service which Acies may
      choose to have supplied by a vendor/partner, Acies may in its sole
      discretion choose which vendor/partner will supply that service. Acies is
      responsible for the fulfillment of each service to each Merchant account
      in a satisfactory fashion.

      o     Paragraph 12 - The Company is involved in the determination of
            product or service specifications.

            As per the list of services noted above, Acies is indeed in the
      business of determining the nature, type, characteristics and/or
      specifications of the services ordered by the customer, the Merchant.

      o     Paragraph 13 - The Company has physical loss inventory risk.

            Not   applicable.

      o     Paragraph 14 - The Company has credit risk.

            Not applicable. The nature of electronic payment processing is such
      that the Company bears no risk of collectibility from its customers, the
      Merchants.

            Indicators of Net Revenue Reporting

      o     Paragraph 15 - The supplier (not the Company) is the primary obligor
            in the arrangement.

            As per Paragraph 7 above, the Company is the Primary Obligor in any
      arrangements with the customer, the Merchant.

      o     Paragraph 16 - The amount that the Company earns is fixed.

            As mentioned earlier, all pricing of the various charges comprising
      Revenue is based on rates set by Acies resulting from an arm's length
      negotiation with each Merchant. These rates have no bearing on the Cost of
      Services, and are completely under Acies' control and set at Acies' sole
      discretion. The principal reason that the Acies' earnings (gross margin)
      varies is our pricing.
<PAGE>

      o     Paragraph 17 - The supplier (and not the Company) has credit risk.

            Not   applicable.

      Based on all of the above criteria, we believe Acies should report its
revenue on a gross basis.

2.       We note your disclosures in Note 6 that the Company entered into a
         3-year marketing agreement with Chase Merchant Services in which Chase
         provides the merchant services and the Company is responsible for
         marketing such services. Tell us if the revenues recognized under this
         arrangement are from merchant services or marketing services and
         explain how you determined that such recognition was appropriate. Also,
         provide a detailed analysis of the specific accounting literature you
         are applying to these arrangements.

         Response:

         Acies' relationship with Chase Merchant Services is discussed in great
detail in our response to Comment #1 (above). Therein, we discuss that our
relationship is such that Chase Merchant Services is a vendor to Acies, and the
fees charged to us by Chase Merchant Services are recognized as expenses which
Acies classifies within Cost of Services.

         The disclosure in Note 6 to the financial statements is worded poorly.
Acies provides merchant services to Merchants as described in great detail in
our response to Comment #1 (above), and Chase Merchant Services is a vendor of
certain services to us. We