Room 4561

      September 1, 2005

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

	Re:	Webb Interactive Services, Inc.
		Post Effective Amendment No. 3 to Form SB-2
		Filed May 13, 2005
		File No. 333-89600

		Form 10-QSB/A for the Fiscal Quarter Ended September 30,
2004
		Form 10-KSB/A for the Fiscal Year Ended December 31,
2004
		Form 10-QSB/A for the Fiscal Quarter Ended March 31,
2005
		Form 10-QSB/A for the Fiscal Quarter Ended June 30, 2005
		Form 8-K/A, filed July 21, 2005
		File No. 00-28462

Dear Mr. Branson:

	We have the following additional comments on your amended
periodic reports.  Please respond to our comments that pertain to
these reports within 10 business days of the date of this letter.

General

1. We have forwarded your response to comment 1 of our letter
dated
June 9, 2005 to the Division of Investment Management.  Any
further
comments will follow under separate cover.


Post Effective Amendment No. 3 to Form SB-2

2. Please note that we will review your responses to comments 2
and 3
of our letter dated June 9, 2005 once you have filed such
responses
along with post-effective amendment number 4 to registration
statement number 333-89600.

Form 10-KSB for the Fiscal Year Ended December 31, 2004, as
amended

Controls and Procedures, page 2

3. While we note the new certifications you have provided in
response
to comment 8 of our letter dated June 9, 2005, we also note that
your
amended Form 10-KSB includes only Items 8A and 9 disclosure, a
signature page, an exhibit index and the certifications required
by
Rules 13a-14(a) and (b).  Please note that the certifications
required by Rules 13a-14(a) and (b) certify, in part, the
financial
statements and related disclosure included in the filing.  Since
the
certifications provided in the initial filing of your Form 10-KSB
did
not meet the requirements of the rules, they did not appropriately
certify the information included in such filing.  Accordingly,
please
file an amendment including a complete version of your 2004 Form
10-
KSB accompanied by the certifications required by Rules 13a-14(a)
and
(b).  This comment also applies to your quarterly report on Form
10-
QSB for the quarter ended March 31, 2005.


Form 8-K/A filed July 21, 2005

4. We reissue comment 14 of our letter dated June 9, 2005 in its
entirety.  With regard to your correspondence dated May 25, 2005,
you
are reminded that you must submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.


*	*	*	*	*


      As appropriate, please amend your filing in response to
these
comments.  Please ensure that your amendment is marked in
accordance
with Item 310 of Regulation S-T.  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.  Detailed cover letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

	You may contact Tamara Tangen at (202) 551-3443 if you have
questions regarding the comments on your Form 8-K/A.  Please
contact
Rebekah Toton at (202) 551-3857 or Sara Kalin at (202) 551-3454
with
any other questions.  If you need further assistance, you may
contact
me at (202) 551-3730.


								Sincerely,


								Mark P. Shuman
								Branch Chief - Legal

cc:	Via Facsimile (612) 632-4024
	Lindley S. Branson, Esq.
	Gray, Plant, Mooty, Mooty & Bennett, P.A.
	Telephone: (612) 632-3024
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Lindley S. Branson
Webb Interactive Services, Inc.
September 1, 2005
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