Mail Stop 4561

October 18, 2005


Stephen Green
Senior Vice President and General Counsel
IHS, Inc.
15 Inverness Way East
Englewood, CO  80112

Re:  	IHS, Inc.
	Amendment No. 6 to Form S-1
		Filed October 6, 2005
	File No. 333-122565

Dear Mr. Green:

We have reviewed your amendment and have the following comments.

General
1. We are reviewing your response to prior comment no.2 in our
letter
dated September 14, 2005 relating to the transaction between the
selling stockholders and the entities affiliated with General
Atlantic LLC. We will respond under separate cover.

Financial Statements

Cash Flow Statements, pages F-6 and F-41
2. Tell us how your presentation of cash flows used in
discontinued
operations is consistent with the guidance in SFAS 95,
specifically
paragraphs 26, 28 and 29.  In this regard, whether or not cash
flows
from discontinued operations are set out separately, the
reconciliation of net income to net cash flows from operations
should
begin with net income as required by paragraphs 28 and 29 of SFAS
95.
Further, if the cash flows relating to discontinued operations are
separately presented, separate disclosure of such cash flows
should
be made within all three categories of cash flows (i.e.,
operating,
investing and financing, when applicable).  Please advise and
revise
as necessary.

Note 22.  Discontinued Operations, page F-37
3. Clarify where you have presented the net assets related to the
discontinued operations in your balance sheets as of November 30,
2003, 2004 and August 31, 2005.  Specifically address why the
November 30, 2004 balance sheet on page F-3 indicates you have no
assets held for sale.

Prior Comment no. 12, Deferred Offering Costs
4. Since the Form S-1 appears to be primarily a selling
shareholder
document and it does not appear that you will receive any proceeds
from this offering, explain to us why you believe it is
appropriate
to continue to defer the respective offering costs.  In this
regard,
costs of an offering should be expensed if no proceeds will be
received in the offering, such as costs associated with a selling
shareholder document.  Please advise and revise as necessary.

    As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  We may have
additional comments based on reviewing your amendment and
responses
to our comments.

    You may contact Lisa Mitrovich, Assistant Chief Accountant, at
202-551-3453, if you have questions regarding comments on the
financial statements and related matters.  Please address all
other
comments to Maryse Mills-Apenteng at 202-551-3457.  If you require
further assistance you may contact the undersigned at 202-551-
3730.

								Sincerely,



								Barbara C. Jacobs
								Assistant Director

cc:	Via facsimile:  212-450-3662
      Richard J. Sandler, Esq.
      Mark Schwartz, Esq.
      Davis Polk & Wardwell


??

??

??

??

Stephen Green
IHS, Inc.
October 18, 2005
Page 2