UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE


Mail Stop 5546
								September 29, 2005

WebMD Corporation
669 River Drive, Center 2
Elmwood Park, NJ

      Re:	WebMD Corporation
      Form 10-K for the Fiscal Year Ended December 31, 2004
		Filed March 16, 2005
      File No. 000-24975

Dear Mr. Corbin:

      We have limited our review of the above filing to
disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and we will make no further review of
the filing.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, we are asking you to provide us with
supplemental information so that we may better understand your
disclosure.  Please be as detailed as necessary in the explanation
you provide for this comment.  After reviewing this information,
we
may or may not raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note from the schedule to Exhibit 10.4 filed with WebMD
Health
Corp`s Form S-1/A on September 8, 2005 that the Trademark License
Agreement will grant you a non-exclusive, registered trademark for
"WebMD" in Cuba and Iran.  We also note from the recitals that you
"previously used the Licensed Marks in the operation of [your]
business."  Please describe for us your previous, existing and
anticipated operations in and contacts with Cuba and Iran,
including
through distributors, subsidiaries, affiliates and any other
direct
or indirect means.  Your response should not be limited to
operations
and contacts related to intellectual property rights.

2. In light of the fact that Cuba and Iran are subject to economic
sanctions administered by the Treasury Department`s Office of
Foreign
Assets Control and identified as state sponsors of terrorism by
the
U.S. State Department, please address the materiality of any
operations, arrangements or other contacts with Cuba and Iran.
Please present your view as to whether any such operations,
arrangements or other contacts constitute a material investment
risk
for your security holders.

In preparing your response please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of qualitative factors that a
reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.  In this regard, we note
that
Arizona and Louisiana have adopted legislation requiring
divestment
from, or reporting of interests in, companies that do business
with
U.S.-designated state sponsors of terrorism.

3. We note that some of your porous plastic products, which are
sold
outside of the U.S., are incorporated into the products of other
manufacturers or custom-built for industrial applications.  Please
describe for us whether your previous, current or anticipated
operations or contacts with Cuba and Iran involve products that
have
a military purpose or, to the best of your knowledge,
understanding
and belief, can be put to military use.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please
understand
that we may have additional comments after reviewing your
amendment
and responses to our comments.  Please file your response letter
on
EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filing; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      Please contact James Lopez at (202) 551-3536 if you have any
questions about the comments or our review.  You may also contact
me
at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk




cc: 	Barbara Jacobs
		Assistant Director
		Division of Corporation Finance
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Mr. Andrew C. Corbin
WebMD Corporation
September 29, 2005
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