September 7, 2007



Securities and Exchange Commission
100 F Street, NE
Washington, D.C.  20549
Attention:  Maryse Mills-Apenteng

     Re:  SPSS Inc.
          Registration Statement on Form S-3
          File Number 333-143802

Ladies and Gentlemen:

     SPSS Inc. hereby requests acceleration of the effectiveness of the
above-referenced registration statement such that it will become effective at
3:00 p.m. on September 7, 2007, or soon thereafter as is practicable.

     The Company hereby 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 this action as a defense in any proceeding
          initiated by the Commission or any person under the federal securities
          laws of the United States.

     Please telephone the undersigned at (312) 612-2077 or David A. Schuette of
Mayer Brown at (312) 701-7363 if you have any questions with respect to the
foregoing.

                                                     Very truly yours,

                                                     SPSS INC.


                                                     /s/ Raymond H. Panza
                                                     ---------------------------
                                                     By: Raymond H. Panza