Soluble, ultra-short (length < 60 nm), carboxylated, single-walled carbon nanotubes (SWNTs) have been prepared by a scalable process. This process, predicated on oleum's (100% H2SO4 with excess SO3) ability to intercalate between individual SWNTs inside SWNT ropes, is a procedure that simultaneously cuts and functionalizes SWNTs using a mixture of sulfuric and nitric acids. The solubility of these ultra-short SWNTs (US-SWNTs) in organic solvents, superacid and water is about 2 wt %. The availability of soluble US-SWNTs could open opportunities for forming high performance composites, blends, and copolymers without inhibiting their processibility.