SecProbe.io

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Mail Stop 3561

									August 8, 2005

Mr. Michael J. Dodak
Chief Executive Officer
Global Axcess Corp.
224 Ponte Vedra Park Drive
Ponte Vedra Beach, FL

      RE:	Global Axcess Corp.
      Form 10-KSB for the Fiscal Year Ended December 31, 2004
      Filed March 31, 2005
      File No. 0-17874

Dear Mr. Dodak:

      We have reviewed your filings and have the following
comments.
We have limited our review to your financial statements and
related
disclosures and will make no further review of your documents.
Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, 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 information so we
may
better understand your disclosure.  After reviewing this
information,
we may 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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the Year Ended December 31, 2004

Signatures, page 44

1. The report must also be signed by your principal accounting
officer in the second signature block.  Any person who occupies
more
than one of the specified positions must indicate each capacity in
which he or she signs the report.  See paragraph 2 of General
Instruction C to Form 10-KSB.  Please tell us if your Chief
Financial
Officer also serves as your principal accounting officer.  If so,
in
future filings please indicate each capacity in which he or she
signs
the report.  If not, please file an amendment containing the
signature of your principal accounting officer.

Consolidated Statements of Income, page F-4

2. We note that you recorded a gain upon cancellation of notes
payable to related parties during 2003.  Please explain to us in
detail the circumstances resulting in the cancellation of the
notes
and the nature of the related party relationship.  Please also
tell
us why the gain was recorded in income as opposed to a capital
contribution.  Please refer to footnote 1 of APB 26.

Notes to Consolidated Financial Statements, page F-9

Note 1 - Description of Business and Summary of Significant
Accounting Policies, page F-9

Revenue Recognition, page F-9

3. Please tell us the amount of revenues from surcharges,
interchange
fees, transaction processing fees, network management fees, sale
of
software and sales of other products including prepaid cellular
services, phone card services, internet services and wire transfer
services for each year presented.  In doing so, please summarize
revenues for ATMs you own and ATMs you manage.  In addition,
please
tell us the products that you purchase from third parties and
resell
through your ATM network.

4. With respect to surcharge and interchange fees from ATMs that
you
manage and each of the products that you purchase and resell
please
explain to us in detail the facts and circumstances that support
recognition of revenue based on the gross amount billed to
customers
as opposed to the net amount retained.  In doing so, please
address
each of the relevant indicators set forth in EITF 99-19.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed decision.  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 do not foreclose the Commission from taking any action
with
respect to the filings; 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.

      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 filings or
in
response to our comments on your filings.

      You may contact Andrew Blume (Staff Accountant) at (202)
551-
3254 or William Thompson (Staff Accountant) at (202) 551-3344 or
in
their absence the undersigned at (202) 551-3716 if you have any
questions regarding these comments.

								Sincerely,

						William Choi
									Accounting Branch
Chief

Mr. Michael J. Dodak
Global Axcess Corp.
August 8, 2005
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