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S.E.C. ACCELERATION REQUEST

UNICA CORPORATION

Reservoir Place North

170 Tracer Lane

Waltham, Massachusetts 02451-1379

                    July 29, 2005

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Judiciary Plaza

450 Fifth Street, N.W.

Washington, D.C. 20549

    Re:

    Unica Corporation

    Registration Statement on Form S-1

    File No. 333-120615

    Request for Acceleration

Ladies and Gentlemen:

     Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Unica
Corporation (the “Registrant”) hereby requests acceleration of the effective date of its
Registration Statement on Form S-1 (File No. 333-120615), as amended (the “Registration
Statement”), so that it may become effective at 3:00 p.m. on August 2, 2005, or as soon thereafter
as practicable.

     The Registrant hereby acknowledges that:

    (1)

    should the Securities and Exchange Commission (the “Commission”) or the staff,
acting pursuant to delegated authority, declare the Registration Statement effective,
it does not foreclose the Commission from taking any action with respect to the
Registration Statement;

    (2)

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

    (3)

    the Registrant may not assert the action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the Registration Statement effective as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

    Very truly yours,

    UNICA CORPORATION

    By:

    /s/ David W. Flynn

    David W. Flynn

    Vice President and Corporate Controller