October
28, 2008
Securities
and Exchange Commission
450
Fifth
Street, N.W.
Washington,
D.C. 20549
| Re: |
Visual
Management Systems, Inc.
|
Registration
Statement on Form S-1
Registration
No. 333-148309
Ladies
and Gentlemen:
Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of
1933, as amended, Visual Management Systems, Inc. (the “Company”) hereby
requests that the effective date of the Registration Statement on Form S-1
referenced above be accelerated to 1:30 p.m. on Tuesday, October 28, 2008 or
as
soon thereafter as practicable.
Further,
the Company hereby acknowledges that: (i) should the Securities and Exchange
Commission (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; (ii) 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 (iii) the
Company may not assert the declaration of the effectiveness as a defense in
any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
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Very
truly
yours, |
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VISUAL MANAGEMENT SYSTEMS, INC. |
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By: |
/s/ Jason
Gonzalez |
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Jason
Gonzalez |
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President
and
Chief Executive Officer |