SecProbe.io

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Mail Stop 3561

									August 31, 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 response filed on August 23, 2005 to
our
comment letter dated August 8, 2005 and have the following
additional
comments.  Please provide a written response to our comments.
Please
be as detailed as necessary in your explanation.  After reviewing
this information, we may raise additional comments.

	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.

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

Consolidated Statements of Income, page F-4
1. We note your response to comment 2 in our letter dated August
8,
2005 and reissue the comment.  Please tell us the circumstances
that
led to the modification of the note.  Please also tell us the
authoritative literature you applied in your determination that
the
debt extinguishment gain should be recorded as income as opposed
to a
capital contribution.  In addition, tell us how you calculated the
gain of $261,023 reflected in your statements of income.  In doing
so, tell us how you determined the fair value of the new debt
instrument.  Please refer to EITF 96-19.  Please provide us a copy
of
the agreement referred to in your response.

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

2. We note your response to comment 4 in our letter dated August
8,
2005.  It appears that your response is inconsistent with
disclosures
throughout your Form 10-K.  For example, you state that you only
record the contractual revenue due to you.  However, you disclose
on
pages 17, 25, 26 and F-9 that you record all surcharge and
interchange fees you receive as revenue for both your owned and
managed ATMs.  In addition, you state that surcharge and/or
interchange fees passed through to merchants are not recorded as
revenue or costs while your disclosure on page 26 indicates that
you
record as a commission all monies paid to the owners of managed
ATMs.
Please clarify these apparent discrepancies and revise your
disclosures in future filings to clearly indicate which revenues
you
record on a gross basis and net basis.  Please show us what your
revised disclosure in future filings will look like.  Please also
confirm to us that interchange and surcharge fees not remitted to
ATM
owners are recorded in your balance sheets.

		Please respond to these comments within 10 business days
or
tell us when you will provide us with a response.  Detailed
response
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your responses to our
comments.

      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
									Branch Chief

Mr. Michael J. Dodak
Global Axcess Corp.
August 31, 2005
Page 1

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