SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>youbetresponse.txt
<DESCRIPTION>SUPPLEMENTAL RESPONSE LETTER
<TEXT>
                            [YOUBET.COM LETTERHEAD]

                                October 15, 2004

VIA FACSIMILE and EDGAR

Beverly A. Singleton
Staff Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.

           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 Ms. Singleton:

    We have received your additional comment to the above referenced Form
8-K, as amended, in a letter dated October 4, 2004 and addressed to Charles
Champion, President and Chief Executive Officer of Youbet.com, Inc. The
remainder of this letter contains the text of your comment followed by our
response, as well as certain requested acknowledgements.

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 [in]
    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.

Response

We filed the requested letter from BDO Seidman today under cover of amendment
no. 2 to our Form8-K originally filed on August 24, 2004.

In the interest of putting the change of our independent accountant to rest, we
have filed a second amendment to our Form 8-K with BDO's letter attached.
However, we would like to supplementally advise the staff that BDO's
recollection of our discussions does not match our recollection. Also, we are
surprised they are unable to comment on a simple mathematical calculation that
is easily verifiable in their work papers. In any event, we hope that our filing
concludes this matter. Thank you for your continued and prompt attention to this
matter.

                                   * * * * *

As requested, Youbet again acknowledges that:

     o   We are responsible for the adequacy and accuracy of the disclosure in
         our SEC filings;

     o   SEC staff comments or changes to disclosure in response to such
         comments in the filings reviewed by the staff do not foreclose the
         SEC from taking any action with respect to any such filing; and

     o   Youbet may not assert staff comments as a defense in any proceeding
         initiated by the SEC or any person under the federal securities laws
         of the United States.

<PAGE>

Beverly A. Singleton
October 15, 2004
Page 2

         If you have any questions regarding our responses, please do not
hesitate to contact me at (818) 668-2274.

                                   Sincerely,

                                   Charles R. Bearchell
                                   ------------------------
                                   Chief Financial Officer

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