SecProbe.io

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August 12, 2005

Mr. William Choi
Accounting Branch Chief
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

RE:   Letter dated August 8, 2005 on Global Axcess Corp's Form 10-KSB for
      the Fiscal Year Ended December 31, 2004 filed March 31, 2005
      File No. 0-17874

Dear Mr.Choi:

We have reviewed your letter and have made the following responses to each of
your comments as numbered.

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 principle 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.

Response. David J. Surette is our Chief Financial Officer. He is also serving as
our Chief Accounting Officer. He has in the latest filing, and will in future
filings, be signing as both the Chief Financial Officer and Chief 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 APB26. Response. The
related party relationship was determined because the note holder was a
shareholder although not holding more than 5% of the Company. The cancellation
of the note was determined to be a gain and recorded into income as opposed to a
capital contribution for the following reasons:

      a.    The note holder was not given any additional equity in the Company
            and was not a related party with 10% or more of ownership of the
            Company.

      b.    For the forgiveness and cancellation of 50% for the original balance
            the Company re-signed a new note with a higher rate of interest,
            over a longer term and paid down the original note with a $25,000
            cash payment.

See the attached Memo written on the entry which refers to SFAS 4 and FAS 145

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 ATM's you own and ATM's you manage. In
addition, please tell us the products that you purchase from third parties and
resell through your ATM network.

Response. The amount of revenues from surcharges, interchange fees, transaction
processing, network management fees, sales of software, and other sales are as
follows:

      ATM's we own:                            2004                 2003
                                           -----------          -----------
a.   Surcharge revenue                     $ 7,285,760          $ 6,149,422
b.   Interchange revenue                   $ 4,484,576          $ 2,102,295

      ATM's we manage:
c.   Management fees                       $ 1,077,723          $ 1,242,170
d.   Transaction Processing & Network
      Management fee revenue               $   176,269          $   439,510

      Products we resell:
e.   Equipment sales(ATMs)                 $   834,399          $   252,578
f.   Card sales(Easy Green
      ATM Debit Cards)                     $     7,950          $         0
      Other revenue:
f.   Software sales                        $    18,102          $    15,244
h.   Other revenue                         $    23,171          $       546
                                           -----------          -----------
                                           $13,907,950          $10,201,765

With in these years we do not show any revenue for items such as phone card
services, internet services or wire transfer services.

4. With respect to surcharge and interchange fees from ATM's 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 ner amount retained. In doing
so, please address each of the relevant indicators set forth in EITF 99-19.
<PAGE>

Response. For ATM's we own, the Company meets all indicators under EITF 99-19
for Gross Revenue Reporting, we book the entire surcharge and interchange as
revenue. Any monies due to merchants for a space lease is paid and booked as an
expense in cost of sales. For ATM's we have sold, the Company meets indicators
of Net Revenue Reporting, and we book only the revenue due to us per the
contract. For example, if a merchant that bought the ATM receives all the
surcharge and we receive all the interchange per the contract, then we only book
the interchange received. The surcharge is passed though to the merchant with no
recording of revenue or costs on our books. For sales of equipment we sell these
basically at our cost or at a loss. For the sale of cards we have a profit of
$1,450.

The Company understands the following: that the Company is responsible for the
accuracy of the disclosure in the filings; staff comments or changes to
disclosures 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.

Thank you for your comments and the Company will continue to work with the
United States Securities and Exchange Commission to have adequate and accurate
disclosure in their filings.

Sincerely,

/s/ Michael J. Dodak
Michael J. Dodak
Chief Executive Officer
<PAGE>

Response 4. Continued. For ATM's we own, the Company meets all indicators under
EITF 99-19 for Gross Revenue Reporting, we book the entire surcharge and
interchange as revenue. Any monies due to merchants for a space lease is paid
and booked as an expense in cost of sales. For ATM's we have sold, the Company
meets indicators of Net Revenue Reporting, and we book only the revenue due to
us per the contract

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Memo

           To:     Audit File
           From:   David J. Surette
           CC:     Weinberg & Co., P.A.
           Date:   7/17/2003
           Re:     Debt Cancellation

--------------------------------------------------------------------------------

As of April 30, 2003 the following unsecured Notes Payable have been reduced and
the debt cancelled see attached agreement (Exhibit 1):

Dr. Robert Mehlmen a stockholder with less than 5% of Global Axcess stock held a
Note in the amount of $487,962.00 and 7.5% interest. In return for an upfront
payment of $25,000 and higher interest rate of 10.5% the note was reduced by 50%
or $243, 981. The cancelled debt is recorded as follows based on SFAS 4
Reporting Gains and Losses from Extinguishment of Debt and FAS 145 (rescinding
SFAS 4) Gains and Losses from Extinguishment of Debt:

                            Dr                Cr

Notes Payable                   $243,981

  Other Income                                243,981

To record Gain on extinguishment of debt

The gain is to be recorded as Other Income and not as an Extraordinary Gain per
FAS 145
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