Second Request

Mail Stop 04-06

      March 22, 2005

Via U.S. Mail

Lindley S. Branson
Vice President and General Counsel
Webb Interactive Services, Inc.
1899 Wynkoop, Suite 600
Denver, CO  80202

Re:   	Webb Interactive Services, Inc.
      Form 8-K filed February 16, 2005
      File No. 000-28462

Dear Mr. Branson:

      As we indicated in our letter of February 17, 2005, we have
reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 8-K filed on February 16, 2005
1. Revise to state the date that the former accountant declined to
stand for re-appointment, as required by Item 304(a)(1)(i) of
Regulation S-B.
2. Revise your disclosures in the third paragraph in order to
specifically identify the interim periods through the date of
Ernst &
Young`s declination to stand for re-appointment, including the
"subsequent interim periods" during which no reportable events, as
defined in Item 304(a)(1)(iv)(B) of Regulation S-B occurred.
3. Please obtain and file an updated Exhibit 16 letter from the
former accountants stating whether the accountants agree with the
statements made in your revised Form 8-K.
* * * * *

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      Any questions regarding the above should be directed to me
at
(202) 942-1987, or in my absence, to Robert Benton at (202) 942-
1811.

Sincerely,


Tamara Tangen
      Staff Accountant
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Webb Interactive Services, Inc.
March 22, 2005
Page 1