UNIFY CORPORATION
1420 Rocky Ridge Drive, Suite 380
Roseville, CA 95834

November 10, 2009

VIA FACSIMILE AND EDGAR

Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 6010
Washington, D.C. 20549

Attention: Michael F. Johnson

Re:	Unify Corporation (the “Company”)
	Registration Statement on Form S-3
	(File No. 333-161645)

Ladies and Gentleman:

     Pursuant to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests that the Commission accelerate the effectiveness of the above-referenced Registration Statement to 5:00 p.m., Eastern Time, on November 12, 2009, or as soon thereafter as practicable, or at such later time as the Company may request by telephone to the Commission. The Company hereby authorizes Kevin Coyle of DLA Piper LLP (US), counsel for the Company, to make such request on our behalf. The Company also hereby requests a copy of the written order verifying the effective date.

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 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.

     Thank you for your assistance. If you should have any questions, please call Kevin Coyle of DLA Piper LLP (US), counsel to the Company, at 916-930-3240.

Very truly yours,
UNIFY CORPORATION.
By:	/s/ Steven Bonham
	Steven Bonham
	Chief Financial Officer