SecProbe.io

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Room 4561
						October 18, 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 your response letter dated September 8,
2005
and have the following additional comments.  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. We have read your response to prior comment number 1.  You
indicate, but do not propose any additional disclosure, that
operating cash flows were affected by the aggressive pursuit of
cash
discounts related to accounts payable and a significant change in
your credit terms resulting from the elimination of an ARC
factoring
arrangement.  In addition, we note that there have been
fluctuations
in working capital items that appear to have been material as
compared to your operating cash flows that are not addressed in
your
current or proposed disclosures.  Disclosing these changes solely
through presenting cash flows using the indirect method does not
provide a sufficient basis for a reader to analyze the changes.
Please explain to us why your proposed disclosures do not address
these issues.

Item 9A. Controls and Procedures, page 25

2. We have read your response to prior comment number 2.
Considering
that you and your auditors believed it necessary to perform
additional manual processes, extended cut-off procedures and
testing
subsequent to year end to mitigate the known deficiencies for
purposes of filing your initial Form 10-K, it remains unclear to
us
how you considered condition (D) of SEC Release 34-50754 as of
April
5, 2005.  Please explain further how you concluded that these
deficiencies should not have been reported in your initial filing
and
how you concluded that your disclosure controls and procedures
were
effective.  In addition, tell us which of the deficiencies
described
in your response to prior comment number 9 were known at April 5,
2005.

Financial Statements

Note 2.  Summary of Significant Accounting Policies

Revenue Recognition, page F-9

3. We have read your response to prior comment number 6. Please
quantify the extent to which you enter into bill and hold
transactions and provide us with the following:

* Describe to us how you conclude that the risks of ownership have
passed to the customer;

* Explain to us how you determine that your customers have
requested
the bill and hold transactions and identify the form in which
these
requests are made; and

* Confirm that there is a stated, fixed delivery schedule.

Form 10-K/A Filed May 5, 2005

Item 9A. Controls and Procedures

4. We have read your response to prior comment number 9 that
provides
the aggregate impact of the unadjusted audit differences. Please
provide us with a schedule that shows each individual unadjusted
audit difference for the fiscal year ended January 5, 2005.

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

Item 4.  Controls and Procedures, page 20

5. We note your response to prior comment number 10 and do not
believe that your disclosure complies with Item 307.  In this
regard,
your disclosure should provide a clear conclusion regarding the
effectiveness as of the end of the period covered by the report.

6. We note your response to prior comment number 11 and believe
that
additional disclosures are necessary if you continue to describe
the
review performed by the third party consulting firm.  Your current
disclosures regarding this review and its preliminary conclusions
appear to contradict the continued existence of the material
weaknesses as described in the body of your Item 9A disclosures.
We
believe that you should provide additional disclosures that
explain
how you expect readers to interpret this information and provide
sufficient qualifying language to avoid any confusion as to how
this
information relates to your current conclusions regarding your
controls.

	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.

	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.
October 18, 2005
Page 4

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