INTERNATIONAL MICROCOMPUTER SOFTWARE, INC.
                            100 ROWLAND WAY SUITE 300
                                NOVATO, CA 94945

VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

Attn:  Hugh Fuller, Examiner

      RE:   REGISTRATION OF SHARES OF INTERNATIONAL MICROCOMPUTER SOFTWARE, INC.
            FOR RESALE BY CERTAIN SHAREHOLDERS, REGISTRATION STATEMENT NO.
            333-119359.

Ladies and Gentlemen:

         International Microcomputer Software, Inc. hereby requests that the
Commissioner take appropriate action to cause the above-referenced Registration
Statement to become effective at 9:30 AM on Thursday, November 4, 2004, or as
soon thereafter as practicable. This request supersedes one submitted
previously.

                                   Very truly yours,

                                   International Microcomputer Software, Inc.

                                   /s/ William J. Bush

                                   By William J. Bush
                                   Chief Financial Officer & Secretary