SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>ltyoubet1.txt
<DESCRIPTION>SEC 10/4/04 COMMENT LETTER RE: 8-K (ITEM 4.01) - SUPPLEMENTAL RESPONSE
<TEXT>

					       October 4, 2004

Stop 0305

BY FACSIMILE  [ (818) 668 - 2101 ]  and  U.S. MAIL

Mr. Charles Champion
  President and Chief Financial Officer
YOUBET.COM, INC.
5901 De Soto Avenue
Woodland Hills, California  91367

	re:	Youbet.com, Inc.
		Supplemental response letter dated September 22, 2004
regarding the
		Forms 8-K (Item 4.01), filed August 24, 2004 and as amended
on September 1, 2004
		File No. 0-26015

Dear Mr. Champion:

	We have reviewed your supplemental response letter to us dated
September 22, 2004 in response to our letter of comment dated
September 16, 2004, and have the following comment that requires an
amendment to the Item 4.01 Form 8-K.

	Please file the amendment immediately.  Pursuant to Rule
101(a)(3) of Regulation S-T, your response, if any, should be
submitted in electronic form, under the label "corresp".

	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 filing.  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.

October 4, 2004

Mr. Charles Champion
Youbet.com, Inc.
Page 2

Item 4.01 of Form 8-K

Exhibit 16 Letter

1. We note your response to prior comment 3; however, the requirements
of Item 304(a)(3) of Regulation S-K require that the former
accountants be provided with a copy of the disclosures you provide in
an Item 4.01 Form 8-K filing, including any subsequent amendments, and
that the former accountants furnish you with a letter addressed to us
stating whether or not it agrees with your disclosures.  As it appears
that BDO Seidman, LLP, your former accountants, have not reviewed the
disclosures contained the Item 4.01 Form 8-K filed on September 1,
2004, your filing does not comply with Item 304 of Regulation S-K, and
is considered deficient.  Please comply by providing BDO Seidman with
a copy of the disclosures contained in the Item 4.01 Form 8-K filed on
September 1, 2004, and amend this filing to provide an updated Exhibit
16 letter from them.

Other

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to be
certain that they have provided all information investors require.
Since the company and its management are in possession of all facts
relating to a 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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

October 4, 2004

Mr. Charles Champion
Youbet.com, Inc.
Page 3

	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.

Closing

	Any questions concerning the above comments may be directed to
the undersigned at (202) 942-1912, or in her absence to Mr. Robert
Benton, Senior Staff Accountant, at (202) 942-1811.

			                                    Sincerely,

						Beverly A. Singleton
						Staff Accountant

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(..continued)

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