NeoMedia Technologies, Inc.

2201 Second Street, Suite 600

Fort Myers, Florida 33901

October 29, 2007

Mr. Mark Schumann

United States Securities and Exchange Commission

100 F Street

Washington, D.C. 20549

 Re: NeoMedia Technologies, Inc. Request for Acceleration of Amendment No. 5 to Registration Statement on Form S-3 File No. 333-137227

Ladies and Gentlemen:

NeoMedia Technologies, Inc. (the “Company) hereby requests acceleration of the effectiveness of its Amendment No. 5 to Registration Statement on Form S-3 (File No. 333-137227), filed on October 12, 2007, as amended, to 5:00 pm on October 31, 2007, or as soon thereafter as practicable.

Please direct any questions or comments regarding this filing to Ronald S. Haligman at (305) 539-3339 or Clayton E. Parker at (305) 539-3306 of Kirkpatrick & Lockhart Preston Gates Ellis LLP, counsel to the Company.

In addition, the Company acknowledges that:

Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

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

The Company may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

NEOMEDIA TECHNOLOGIES, INC.
By:	/s/ Frank Pazera
	Frank Pazera Chief Financial Officer