Comment Letter

PAGE 91/03 PERVASIVE SOFTWARE March 7,2006 Facsimile: 202-772-9324, Attn: Federal Advisory Committee Management Officer The Honorable Christopher Cox Chairman U.S. Securities and Exchange Commission 100 F Street, NE Washinaton. DC 20549-1070 Subject: Comments on File Number 26523 I MAR 0 9 2006 I Dear Chairman Cox: Iam writing to you on behalf of Pervasive Software Inc. (NASDAQ: PVSW). My current position with the Company is Director. President and Chief Executive Officer effective January 2006. Prior to that. Iserved the Company as Chief Financial Officer since July 2001. Prior to joining Pervasive in 1994.1 was a CPA in the Audit department of KPMG Peat Marwick for more than 12 years Pervasive Software is a micro-cap company wah tralling twelve-month revenues of $48M and a market capitalization of 596M as of March 6,2006. We are a software development company . . incorporated in January 1994 and became a public company with our initial public offering in September 1997. We employ 230 individuals throughout the world, 160 of which are located in our home office in Austin. Texas. Pervasive's fiscal year end is June 30 and as such, we completed our first SOX Section 404 Audit for the fiscal year ended June 30,2005 (with clean, unqualified audit reports) and will soon begin incurring outside auditor costs related to our Section 404 audit for the 2006 fiscal year. With cash and securities of approximately $41M, we have an enterprise value of $55M, ...