SecProbe.io

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New York, NY 10005

Note: Acies Corporation has claimed confidential treatment of portions of this
letter in accordance with 17 C.F.R. ss. 200.83

December 5, 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 November 7, 2005 relating
to the Annual Report on Form 10-KSB for Fiscal Year Ended March 31, 2005 of
Acies Corporation ("Acies or the Company"), and as a follow-up to the comments
relating to the same received by Acies on August 15, 2005 and our response to
you dated August 26, 2005. All of the aforementioned documents are incorporated
herein by reference.

Note 1-Summary of Significant Accounting Policies

Revenue Recognition, page F-6

1. With regards to your response to our previous comment no. 1, please explain
the following:

      o     We [note] that the Company considers itself the primary obligor in
            the arrangements with your merchant customers. Is Chase Merchant
            Services, LLC or Paymentech, LP a party to your contracts with the
            merchant customers, in any form? Provide a sample of a merchant
            contract where (a) Chase Merchant Services will process the
            merchants' transactions and (b) where Paymentech will provide such
            services.
<PAGE>

      o     If the merchant has a question or problem regarding the processing
            of their sales transactions do they ever contact Chase Merchant
            Services or Paymentech directly?

      o     Provide a copy of your agreement with both Chase Merchant Services
            and Paymentech.

      Response:

      The Company has supplementally filed with the Staff samples of merchant
      contracts relating to an account serviced by Chase Merchant Services
      (Supplemental Exhibit A) and an account serviced by Paymentech
      (Supplemental Exhibit B). As is evident, those companies to which Acies
      has directed the merchant account to be processed are parties to the
      respective agreements. In addition, the Company has supplementally filed
      with the Staff sample monthly statements sent to merchants as follows: A
      statement for an account processed by Chase (Supplemental Exhibit A-1) and
      a statement for an account processed by Paymentech (Supplemental Exhibit
      B-1). Notwithstanding the contractual language, in practice Acies is the
      single point of contact for our merchants. The statements received by
      merchants are "Acies" statements with our customer support contact
      information. The responsibilities of Acies with regard to merchants are
      detailed within the following master agreements, which the Company has
      supplementally filed with the Staff: Marketing Agreement to which the
      parties are Acies (formerly known as GM Merchant Solutions), Chase
      Merchant Services and JP Morgan Chase Bank (Supplemental Exhibit C);
      MasterCard, Member, MSP Agreement to which the parties are Acies, JP
      Morgan Chase and MasterCard International (Supplemental Exhibit D);
      Paymentech Preferred Card Processing Agreement to which the parties are
      Acies and Paymentech, L.P. (Supplemental Exhibit E); and Paymentech
      Network Card Processing Agreement to which the parties are Acies and
      Paymentech, L.P. (Supplemental Exhibit F).

      In the event that a merchant has a question or problem regarding the
      processing of their sales transactions, equipment, funds, or virtually
      anything else, the merchant always contacts an Acies representative. The
      merchant is instructed to do this by the Acies sales representative who
      provides initial training and set-up, and this is reinforced by the
      merchant receiving the Acies Welcome Kit, which among much other content
      specifically explains how to contact the correct personnel at Acies in
      order to resolve any issues or answer any questions (see pages 2 and 4 of
      Acies Welcome Kit, which the Company has supplementally filed with the
      Staff as Supplemental Exhibit G). The vast majority of the transactions
      processed by our merchants are Visa and MasterCard transactions. The only
      phone number in the Welcome Kit relating to these transactions that does
      not go directly to Acies is for Visa/MasterCard voice authorization of
      specific transactions, which are directed to First Data Corp., who
      performs transaction authorization on our behalf. As a matter of
      practicality, merchants never contact Chase Merchant Services or
      Paymentech directly. In the rare instance where Acies decides that the
      merchant needs to be in direct contact with Chase, Acies is charged for
      that contact and such charge is not passed on to the merchant (See
      Supplemental Exhibit C, Schedule A [last page of exhibit], Item 5723).
<PAGE>

      Further to our previous response to your initial comments and your comment
      to which we are currently responding, Acies believes that our accounting
      for revenues on a gross basis is appropriate based on generally accepted
      accounting principles, including the application of the criteria listed in
      EITF 99-19, which we previously addressed. In addition, Acies believes
      that revenue reporting on this basis is also appropriate based on it being
      consistent with what we believe to be the standard practice for other
      reporting companies within our industry, i.e., our competitors. We have
      compiled excerpts from the disclosures made by two of our publicly held
      competitors, iPayment, Inc. and Pipeline Data, Inc., in their most
      recently filed respective Forms 10-K, which is attached as Exhibit H.
      (Other publicly held competitors follow the same standard practice, but we
      have limited this exhibit to illustrate the above two representative
      competitors). The exhibit includes disclosures relating to: (a) Revenue
      Recognition, (b) Merchant Services and Relationships, and (c) Third Party
      Relationships. Acies has compiled and filed this information because it
      believes that it is conducting virtually the same business as these (and
      other publicly held) competitors, utilizing virtually the same business
      model, and having virtually the same relationships with merchants, sponsor
      banks, card associations and processing providers. As such, since
      investors would likely compare the financial results reported by Acies to
      those of our publicly held competitors, Acies believes it appropriate that
      we report our financial results on a comparable basis to these
      competitors, most of which were established prior to Acies being a
      publicly held company.

      The common denominators in these competitors' rationale for reporting
      revenue on a gross basis are (a) the portability of merchant accounts and
      (b) that the reporting company has ultimate responsibility for the
      merchant. Acies' having merchant account portability is illustrated in the
      following two citations: (1) Supplemental Exhibit C, Paragraph 10(b) (page
      7 of exhibit); and (2) Supplemental Exhibit E, Paragraph 11.4 (page 5 of
      exhibit). In practice, there have been a number of occasions where, to
      better service a particular merchant, Acies has moved that merchant's
      account from one of our third party processing providers to a different
      third party processing provider. In addition, as discussed above and in
      our previous response to the Commission, Acies does indeed have ultimate
      responsibility for the merchants to whom we provide services. Acies shares
      the same key characteristics as those of our competitors, and we agree
      with the revenue recognition and presentation rationale stated by those
      competitors.

      We would appreciate the opportunity to further address the Commission's
      questions and concerns in the clearest possible fashion through a
      conference call, which would enable an interactive exchange and a
      mechanism for follow-up questions to be addressed most efficiently. If
      possible, we would like such a call to be scheduled, as soon as possible,
      for a time that is most convenient for you.
<PAGE>

      Very truly yours,

      /s/  OLEG FIRER                                  /s/  JEFFREY A. TISCHLER
      -----------------------------------              ------------------------
      Oleg Firer                                       Jeffrey A. Tischler
      President and Chief Executive Officer            Chief Financial Officer
<PAGE>

                                                 EXHIBIT H - COMPETITOR ANALYSIS

<TABLE>
<CAPTION>
                                                    REVENUE RECOGNITION
               Note: Information herein should only be considered a reference to the SEC filings indicated.
<S>                    <C>                                                     <C>
------------------------------------------------------- -----------------------------------------------------
                IPAYMENT, INC. (IPMT)                                PIPELINE DATA, INC. (PPDA)
   Source: Excerpted from Form 10-K for Year Ended       Source: Excerpted from Form 10-KSB for Year Ended
                       12/31/04                                               12/31/04
------------------------------------------------------- -----------------------------------------------------
We follow the requirements of EITF 99-19.  Generally,   We follow the requirements of EITF 99-19.
where we have merchant portability, credit risk and     Generally, where we have merchant portability, and
ultimate responsibility for the merchant, revenues      ultimate responsibility for the merchant, revenues
are reported at the time of sale on a gross basis       are reported at the time of sale on a gross basis
equal to the full amount of the discount charged to     equal to the full amount of the discount charged to
the merchant.  This amount includes interchange paid    the merchant.  This amount includes interchange
to card issuing banks and assessments paid to credit    paid to card issuing banks and assessments paid to
card associations pursuant to which such parties        credit card associations pursuant to which such
receive payments based primarily on processing volume.  parties receive payments based primarily on
Revenues generated from certain acquired portfolios     processing volume.
are reported net of interchange, where we may not
have credit risk, portability or the ultimate
responsibility for the merchant accounts.
------------------------------------------------------- -----------------------------------------------------
                                                        Revenues are reported gross of amount paid to
                                                        sponsor banks as well as interchange and
                                                        assessments paid to credit card associations under
                                                        revenue sharing agreements pursuant to which such
                                                        parties receive payments based primarily on
                                                        processing volume.
------------------------------------------------------- -----------------------------------------------------
</TABLE>

<PAGE>

<TABLE>
<CAPTION>
                                             MERCHANT SERVICES & RELATIONSHIPS
               Note: Information herein should only be considered a reference to the SEC filings indicated.

------------------------------------------------------- -----------------------------------------------------
                IPAYMENT, INC. (IPMT)                                PIPELINE DATA, INC. (PPDA)
   Source: Excerpted from Form 10-K for Year Ended       Source: Excerpted from Form 10-KSB for Year Ended
                       12/31/04                                               12/31/04
<S>                    <C>                                                     <C>
------------------------------------------------------- -----------------------------------------------------
Merchant Services:                                      Merchant Services:
o        Application Evaluation/                        o        Application Evaluation/ Underwriting
           Underwriting.                                o        Merchant Set-Up and Training.
o        Merchant Set-Up and Training.                  o        Card transaction Processing - OUTSOURCED.
o        Transaction Processing - OUTSOURCED .          o        Risk Management/Detection of Fraudulent
o        Risk Management/Detection of Fraudulent                 Transactions.
         transactions.                                  o        Merchant Service and Support.
o        Merchant Service and Support.                  o        Chargeback Service - OUTSOURCED.
o        Chargeback Service.                            o        Merchant Reporting.
o        Merchant Reporting.
------------------------------------------------------- -----------------------------------------------------
Merchant Agreements:                                    Merchant Agreements:
o        Duration - 1 or 2 years with automatic         o        Duration - 1 or 2 years with automatic
         renewal for additional one-year periods.                renewal for additional one-year periods.
o        Sponsoring banks are a party to the            o        Sponsoring banks are a party to the
         agreements.                                             agreements.
o        Sponsoring banks or merchants may terminate    o        Sponsoring banks or merchants may
         the agreement with 30 days notice.                      terminate the agreement on 30 days notice.
o        Termination fees paid by merchants.            o        Termination fees paid by merchants
------------------------------------------------------- -----------------------------------------------------
                                                        Other:
                                                        Currently, we are only responsible for fraudulent
                                                        credit card transactions of our merchants on less
                                                        than 20% of our merchant customers.
------------------------------------------------------- -----------------------------------------------------
</TABLE>

<PAGE>

<TABLE>
<CAPTION>
                                                 THIRD PARTY RELATIONSHIPS
               Note: Information herein should only be considered a reference to the SEC filings indicated.

------------------------------------------------------- -----------------------------------------------------
                IPAYMENT, INC. (IPMT)                                PIPELINE DATA, INC. (PPDA)
   Source: Excerpted from Form 10-K for Year Ended       Source: Excerpted from Form 10-KSB for Year Ended
                       12/31/04                                               12/31/04
<S>                    <C>                                                     <C>
------------------------------------------------------- ----------------------------------