Cimarron Software, Inc.

15 South 1200 East

Salt Lake City, UT 84102

July 11, 2012

Securities and Exchange Commission

Attn:  Barbara C. Jacobs, Assistance Director; Ryan Houseal, Attorney-Advisor

Division of Corporation Finance

Washington, D.C. 20549

Re:         Cimarron Software, Inc.

Registration Statement on Form S-1

Filed May 14, 2012

File No. 333-181388

Dear Ms. Jacobs and Mr. Houseal,

In response to your letter dated June 8, 2012, we respectfully submit the following response:

General

1.   Please update your financial statements and the related disclosure pursuant to Rule 8-08 of Regulation S-X.

RESPONSE:  We have updated the financial statements and related disclosures as instructed.

2.   Since you appear to qualify as an “emerging growth company,” as defined in the Jumpstart Our Business Startups Act, please disclose on your prospectus cover page that you are an emerging growth company.  See Question 1 of Jumpstart Our Business Startups Act Frequently Asked Questions, available on our website at http://sec.gov/divisions/corpfin/guidance/cfjjobsactfaq-title-i-general.htm.  In addition, consider describing the extent to which any of the exemptions available to you as an emerging growth company are also available to you as a Smaller Reporting Company.

RESPONSE:  We have disclosed on our cover page that we are an emerging growth company.

3.   It appears that you do not intend to register a class of securities under Section 12 of the Securities Exchange Act.  As such, please include a risk factor that informs potential investors that you will not be a fully reporting company and will only comply with the limited reporting requirements imposed on Section 15(d) registrants.  Briefly explain how those reports vary from those imposed on fully reporting issuers.

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RESPONSE:  We do intend to register a class of securities under Section 12(g) of the Securities Exchange Act and intend to file an appropriate Form 8-A upon the effectiveness of our registration statement on Form S-1.

4.   It appears reasonably likely that you will have less than five hundred record holders at your next fiscal year end and at the conclusion of the offering.  As such, it appears that there is a significant risk that your reporting obligations under Section 15(d) of the Securities Exchange Act will be suspended under that statutory section and you will not be required to provide periodic reports following the Form 10-K that will be required for the fiscal year in which your registration statement becomes effective.  Tell us what consideration you have given to providing a risk factor that addresses these circumstances and the resulting risks to potential investors.

RESPONSE:  As we will be filing a Form 8-A, we will be required to provide periodic reports.

5.   You state in Note 9 to your financial statements that the conversion price for the Series A preferred stock is $1.20 per share.  Article III, section 2(c)(i) of your Articles of Amendment, filed as Exhibit 3.4, however, states that the conversion price for the Series A preferred stock is $0.83.  Please explain this inconsistency.

RESPONSE:  We have corrected this inconsistency to reflect the correct conversion price.

About the Company

Use of Certain Defined Terms and Treatment of Stock Split, page 6

6.   Your heading references “treatment of stock split,” however, we cannot locate any other discussion of a “stock split.”  Please advise or revise.

RESPONSE:  We have revised as instructed.

Risk Factors, page 6

General

7.   Several of your risk factors could apply to any issuer or any offering.  We note, by way of example, the risk factor disclosure under the following headings:

“Difficult economic conditions could harm our business”; and “Our business operations may be affected by legislative or regulatory changes.”

Please revise your risk factor disclosure as necessary so that each risk factor discussion explains how the risk may affect your operations or the shares being offered.  See Item 503(c) of Regulation S-K.  Generic risk factor discussions that do not describe how a specific risk applies to your company or to an investment in the offering are not helpful to an understanding of the risk.  Please revise as necessary.

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RESPONSE:  We have revised as instructed.

8.   As a related matter, revise your document as necessary so that the heading for each risk factor clearly and concisely describes the related risk.

RESPONSE:  We have revised as instructed.

9.   Consider including risk factor disclosure describing the terms of your Series A preferred stock and how any preferential terms for the preferred stock may adversely affect holders of your common stock.

RESPONSE:  We have added an additional risk factor regarding our Series A preferred stock.

10.   We note that a single customer that is also a related party accounted for approximately 62% of your revenue in 2011 and 43% of your total revenue in 2010.  Your amended filing should include risk factor disclosure that informs potential investors of this relationship.  Here, and elsewhere as appropriate, disclose whether the transactions were at arm’s length and if so, how this evaluation was made.

RESPONSE:  We have revised as instructed.

“Our growth plan is based upon Management’s projection of what may happen in the future, and such predictions may not occur...”, page 7

11.   The safe harbor for forward-looking statements provided in the Private Securities Litigation Reform Act of 1995 does not apply to statements made in connection with an initial public offering.  See Securities Act Section 27A(b)(2)(D) and Exchange Act Section 21E(b)(2)(D).  Therefore, please delete references to forward-looking statements or state explicitly that the safe harbor protections it provides do not apply to statements made in connection with the offering.

RESPONSE:  We have revised as instructed.

Risks Relating to Regulation of Our Business and Our Structure

“Our business operations may be affected by legislative or regulatory changes”, page 8

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12.   You discuss your uncertainty as to how government regulation may affect your ability to compete in the real estate industry.  Your business is described throughout your document, however, as providing laboratory workflow systems.  Please advise or revise your document throughout so as to accurately and consistently describe your business.

RESPONSE:  We have revised as instructed.

“Our shares will be listed for trading on the OTC Bulletin Board...”, page 8

13.   You state in this risk factor heading that your shares will be listed for trading on the OTCBB.  Please revise your document throughout so as to consistently describe the status of having your shares quoted on the OTCBB.  In this regard, we refer to the cover page of your registration statement where you advise readers that “there can be no assurance that a market maker will agree to file the necessary documents with the Financial Industry Regulatory Authority (“FINRA”), which operates the OTC Electronic Bulletin Board, nor can there be any assurance that such an application for quotation will be approved.”

RESPONSE:  We have revised as instructed.

“There may be deficiencies with our internal controls that require improvements, and we will be exposed to potential risks...”, page 10

14.   You should generally avoid mitigating language in risk factor discussions, such as clauses that begin with "while," "although" or "however." In this regard, we note the first sentence under this risk factor heading beginning with While we believe that we currently have adequate internal control procedures in place.... See Staff Observation in the Review of Smaller Reporting Company IPOs, available on our website at http://www.sec.gov/divisions/corpfin/guidance/cfsmallcompanyregistration.htm.

RESPONSE:  We have revised as instructed.

15.   We note your belief that you currently have “adequate” internal control procedures in place.  Please revise to clarify whether the internal control procedures that you currently have in place are the equivalent of internal control over financial reporting as defined in paragraph (f) of Exchange Act Rule 13a-15.

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RESPONSE:  We have revised as instructed.

16.   Your use of the word “adequate” to describe your assessment of your internal control procedures does not provide a clear conclusion as to whether the internal control procedures and testing that you have completed can be considered “effective” as defined in paragraph (f) of Exchange Act Rule 13a-15.  Internal controls over financial reporting are either effective or they are ineffective.  When describing the efforts that you have made to establish the state of your internal controls over financial reporting, and any conclusion as to their effectiveness, please do not use language that suggests effectiveness if that is not your conclusion

RESPONSE:  We have revised as instructed.

17.   Finally, please revise this risk factor to clearly indicate that you will not be required to provide management’s report on the effectiveness of your internal controls over financial reporting until your second annual report, and that you will be exempt from the auditor attestation requirements concerning any such report so long as you are an emerging growth company and/or a smaller reporting company.

RESPONSE:  We have revised as instructed.

"We are an “emerging growth company” under the JOBS Act of 2012, and we cannot be certain if the reduced disclosure...", page 11

18.   We note that you have chosen to take advantage of the extended transition period for complying with new or revised accounting standards.  Please revise to further state in this risk factor that as a result of this election, your financial statements may not be comparable to companies that comply with public company effective dates.  Include a similar statement in your critical accounting policy disclosures.

RESPONSE:  We have revised as instructed.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Liquidity and Capital Resources, page 18

19.   You state that in order to meet your cash needs over the next twelve months, you may increase your credit facility.  We can find no other reference to a credit facility in yourregistration statement.  Please advise or revise.  To the extent that you have a credit facility, please provide quantitative disclosure regarding the current limit on the amount you are allowed to borrow under this credit facility and what amount, if any, has been borrowed under the credit facility.  You should also describe other material terms of the credit facility such as the interest rate applied to funds borrowed under the credit facility and when you are required to pay back any funds that you have borrowed to date.

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RESPONSE:  We have revised as instructed.

20.   We note from your disclosures that you believe the cash on hand may not be adequate to satisfy your ongoing working capital needs.  Disclosure in the liquidity and capital resources section should include the minimum period of time that you will be able to conduct planned operations using currently available capital resources, and the minimum dollar amount of funding you require to conduct your proposed operations for a minimum period of one year.  Quantitative information about your financial requirements and the amount on hand as of the date of your filing will help investors assess the company’s financial condition and the likelihood you will be able to pursue your business plan.  We refer to Item 303(a)(1) of Regulation S-K and SEC Release 33-8350.

RESPONSE:  We have revised as instructed.

Business and Recent Developments, page 20

21.   You state that your company was founded in 1995 “using technology based on work begun at the University of Utah Human Genome Center.”  Please expand this disclosure to describe in greater detail the relationship between your company and the Human Genome Center.  Describe what role the work done by the Human Genome Center played in your company’s development.  We note that your sole executive officer and one of your directors were both involved with the Human Genome Center prior to the founding of your company.

RESPONSE:  We have revised as instructed.

22.   In addition, briefly describe the nature your ownership interest in the technology that is based on work begun at the University of Utah Human Genome Center.  For example, any limitations or encumbrances on your ownership of the technology should be described. You should also discuss how any limitations on your ownership of the technology may affect your operations.

RESPONSE:  We have revised as instructed.

Certain Relationships and Related Transactions, page 28

23.   Please provide your analysis as to why the discussion contained in note 3 to your financial statements should not be included under this item pursuant to Item 404(d) of Regulation S-K.

RESPONSE:  We have revised this section to include the Note 3 discussion.

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Plan of Distribution, page 30

24.   You state that the selling stockholders may sell their shares of common stock on any stock exchange, market or trading facility on which the shares are quoted, and that such sales may be at fixed or negotiated prices.  Please revise to clearly indicate that the selling shareholders may sell their shares at the fixed price of $0.50 per share until your shares are quoted on the OTCBB. In this regard, we refer to the outside cover page of your prospectus.

RESPONSE:  We have revised as instructed.

Item 16. Exhibits

Exhibit 5.1

25.   Please revise the opinion of counsel as to the legality of the securities being registered so that it also opines as to whether the securities were legally issued, fully paid and non- assessable at the time the securities were acquired as described in you selling security holder disclosure.

RESPONSE:  We have revised as instructed.

We thank you for your patience.  If you have any questions or concerns, please feel free to contact our counsel, Vincent & Rees, via telephone at (801) 303-5730.  Thank you for your assistance and review.

Sincerely,

/s/ David Fuhrman

David Fuhrman

Chief Executive Officer

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