Mail Stop 3561

April 3, 2006

Joseph A. Falsetti
President and Chief Executive Officer
Cenuco, Inc.
2000 Lenox Drive, Suite 202
Lawrenceville, New Jersey 08648

Re: 	Cenuco, Inc.
Revised preliminary proxy materials filed March 24, 2006
File No. 1-32187

Dear Mr. Falsetti:

      We have reviewed the filings above and have the following
comments.  We have limited our review to the proposals in your
Preliminary Schedule 14A and related matters.  Where indicated,
please amend your filings in response to these comments.  Please
address all remaining comments in future filings.  If you disagree
with any of these comments, we will consider your explanation as
to
why our comment is inapplicable or a revision is unnecessary.
Please
be as detailed as necessary in your explanation.  In some of our
comments, we may ask you to provide us with supplemental
information
so we may better understand your disclosure.  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. As stated in prior comment 1 of our letter dated March 17,
2006,
we believe that, by operation of Note A, the proxy statement
should
contain all of the information required by Item 14 of Schedule
14A.
We also note that you continue to incorporate by reference much of
the information required by Item 14, such as the historical and
pro
forma financial information and other information about the
parties
to the transaction.  As it does not appear that you are eligible
to
incorporate financial statements or other information by reference
into this Schedule 14A pursuant to Item 14(e) of Schedule 14A and
Parts A, B and C of Form S-4, please revise to include this
information in the proxy statement.

Factors Considered by the Board of Directors of Cenuco, page 38

2. We have considered your revisions in response to prior comment
7.
Please revise the board`s reference to vFinance`s opinion in the
third bullet on page 38 to specifically note that:
   * several of the advisor`s analyses resulted in very wide
ranges
of values; and
* the results of the discounted cash flow analysis suggest that
the
Cenuco shareholders should have received a considerably higher
percentage ownership in the combined entity than the 35% they
received, based on the company`s market capitalization at the date
of
the fairness opinion.

Also revise to explain how the board was able to determine that
the
merger with Hermes was in the best interest of Cenuco stockholders
despite the results of these analyses.  In this regard, the
information provided in your response to prior comment 7 may be
appropriate.


*   *   *   *   *


      Please amend your Preliminary Schedule 14A in response to
these
comments.  You may wish to provide us with marked copies of the
amendments to expedite our review.  Please furnish a response
letter
with your amendments that keys your responses to our comments and
provides any requested supplemental information.  Detailed
response
letters greatly facilitate our review.  Please submit your
response
letter as correspondence on EDGAR.  Please understand that we may
have additional comments after reviewing your amendments and
responses to our comments.

      Please feel to contact me at (202) 551-3833 with any
questions.


Sincerely,



Michele M. Anderson
Legal Branch Chief



Mr. Joseph A. Falsetti
Cenuco, Inc.
April 3, 2006
Page 2