Edward L. Marney
                               121 Hillcrest Drive
                              Stuart, Florida 34996


                                February 16, 2007

VIA EDGAR AND TELECOPY DELIVERY
Filing Desk
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20005

Attention:  Barbara C. Jacobs, Assistant Director

                    Re: Magnitude Information Systems, Inc.
                        Amendment No. 5 to Registration Statement on Form SB-2
                        Commission File No. 333-138961

Dear Assistant Director Jacobs:

      On  behalf of  Magnitude  Information  Systems,  Inc,  we hereby  request,
pursuant  to  Rule  461 of the  Securities  Act of  1933,  that  the  Commission
accelerate the effectiveness of the Company's Form SB-2 registration  statement,
as amended,  Commission File No. 333-138961, and issue an order of effectiveness
as of 4:00 p.m., eastern time, February 16, 2007.

      In connection with the foregoing request for acceleration of the effective
date of the subject pending  registration  statement,  management of 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  adequacy and  accuracy of the  disclosure  in the
filing; and

      - the Company may not assert the staff  comments  and 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.

                                       Very truly yours,
                                       Magnitude Information Systems, Inc.

                                       By: /s/ Edward L. Marney
                                           ----------------------
                                           Edward L. Marney
                                           President and Chief Executive
                                           Officer

cc Daniel Lee, Esq., Staff
   Securities and Exchange Commission