X0202 4 2004-10-25 0 0001017526 ACE COMM CORP ACEC 0001280276 TINMOUTH MICHAEL 704 QUINCE ORCHARD ROAD GAITHERSBURG MD 20877 0 1 0 0 Sr. Vice President Employee Stock Option (right to buy) 1.75 2004-10-25 4 A 0 25000 A 2014-10-26 Common Stock 25000 115000 D Option granted pursuant to the Company's Amended and Restated Omnibus Stock Plan. Option shares vest and become exercisable as of March 1, 2005, based on achievement of certain performance targets for calendar year 2004. If performance targets are not met, option shares will vest seven years from the date of grant. not applicable Loretta L. Rivers, by Power of Attorney for Michael Tinmouth 2004-11-22