SecProbe.io

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Room 4561
						August 24, 2005

Mr. Michael E. Rohrkemper
Chief Financial Officer and
Chief Accounting Officer
Pomeroy IT Solutions, Inc.
1020 Petersburg Road
Hebron, KY 41048

Re:	Pomeroy IT Solutions, Inc.
	Form 10-K for Fiscal Year Ended January 5, 2005
	Filed April 5, 2005
      Form 10-K/A for Fiscal Year Ended January 5, 2005
	Filed May 5, 2005
      Form 10-Q for Fiscal Quarter Ended July 5, 2005
	Filed August 15, 2005
	File No. 000-20022

Dear Mr. Rohrkemper:

      We have reviewed the above referenced filings and have the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  We may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  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-K for the Fiscal Year Ended January 5, 2005

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Liquidity and Capital Resources, page 23

1. Your discussion of operating cash flow appears to be limited to
disclosure of the outstanding balances under your floor plan
arrangements. When preparing the discussion and analysis of
operating
cash flows, you should address material changes in the underlying
drivers that affect these cash flows. These disclosures should
also
include a discussion of the underlying reasons for changes in
working
capital items that affect operating cash flows. Please tell us how
you considered the guidance in Section IV.B.1 of SEC Release 33-
8350.

Item 9A. Controls and Procedures, page 25

2. We note that you identified two material weaknesses that
existed
as of January 5, 2005 in your report on internal control over
financial reporting filed in your amended Form 10-K in accordance
with SEC Release 34-50754.  Please address the following:
* Explain to us when you identified or became aware of these
material
weaknesses and whether you performed any additional mitigating
procedures to ensure that the information provided in your Form
10-K
filed on April 5, 2005 was accurate and that your CEO and CFO were
able to provide the required certifications;
* Explain to us whether your auditors considered the material
weaknesses in determining the nature, extent and timing of audit
procedures performed in support of their opinion on your financial
statements dated March 31, 2005;
* Explain the basis for your conclusion that your disclosure
controls
and procedures were "effective" as of January 5, 2005, as
disclosed
in your initial Form 10-K, considering the material weakness
disclosures that were made only one month later.  Explain how this
conclusion is consistent with the material weaknesses and
ineffective
disclosure controls and procedures disclosed in your amended Form
10-
K; and
* Explain how you considered condition (D) of SEC Release 34-50754
as
it related to your Item 9A disclosures made on April 5, 2005.

Financial Statements

Note 2.  Summary of Significant Accounting Policies

Revenue Recognition, page F-9

3. Please describe to us the extent to which you sell software as
part of your arrangements and indicate whether you account for any
such sales in accordance with SOP 97-2. For arrangements that
include
software and are not accounted for under SOP 97-2, explain how you
considered paragraph 2 of the SOP.

4. We note that you resell certain products from your vendor
partners. Please identify the products that you resell, quantify
these transactions and tell us whether you record this revenue on
a
gross or net basis. Refer to EITF 99-19 in your response.

5. We note that you provide warranty services on behalf of OEM
customers and that you are reimbursed for any costs you incur.
Please explain to us how you are accounting for these transactions
and refer to the authoritative literature that supports your
accounting.

6. Please tell us more about your logistical deployment services
arrangements. Describe the products and services provided and the
material contract terms offered. Refer to the accounting
literature
that supports your revenue recognition policies for these
arrangements and explain to us how your policies comply with that
literature.

7. Please describe your "service contracts" to us and explain why
you
believe it is appropriate to recognize revenue relating to these
contracts ratably.

8. In appears from your disclosure regarding multiple-element
arrangements that you consider each deliverable (e.g., equipment,
configuration, training, installation, etc.) to be a separate unit
of
accounting. Please explain to us how these deliverables meet the
criteria in paragraph 9 of EITF 00-21 in order to be considered
separate units of accounting.

Form 10-K/A Filed May 5, 2005

Item 9A. Controls and Procedures

9. Please tell us more about the material weakness related to
appropriately applying generally accepted accounting principles.
Clarify whether this weakness is limited to the reconciliation and
classification issues that are described in your disclosure. In
addition, describe the specific issues to us in more detail,
identify
the accounts and reporting periods affected, and quantify the
adjustments that were required.

Form 10-Q for Fiscal Quarter Ended July 5, 2005

Item 4.  Controls and Procedures

10. We note that you refer to the conclusion that your controls
and
procedures were not effective as of January 5, 2005, but you do
not
appear to provide a conclusion regarding the end of the period
covered by this report.  Please explain to us how you complied
with
Item 307 of Regulation S-K for each of your quarterly reports that
have been filed in fiscal 2005.

11. We note that you disclose that a review was performed by a
third-
party consulting firm and that "the systems and processes reviewed
and validated were considered sufficient from an internal control
standpoint."  Please explain to us how readers should interpret
this
information and indicate the specific guidance you are following
in
making these disclosures.

12. You refer to taking steps to enhance your internal controls
over
financial reporting.  Please describe to us the steps you have
taken
(or plan to take) and procedures you have implemented (or plan to
implement) to correct each material weakness. Indicate when each
corrective action was completed or is expected to be completed.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment 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 any amendment and your responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain 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 filing;

* staff comments or changes to disclosure in response to staff
comments 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.

      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.

	You may contact Christine Davis, Staff Accountant, at (202)
551-
3408, Mark Kronforst, Senior Staff Accountant at (202) 551-3451 or
me
at (202) 551-3489 if you have questions regarding these comments.

Sincerely,

      Brad Skinner
							Accounting Branch Chief
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Mr. Michael E. Rohrkemper
Pomeroy IT Solutions, Inc.
August 24, 2005
Page 5

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