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POMEROY
    IT SOLUTIONS

                                                            1020 Petersburg Road
                                                            Hebron, KY 41048
                                                            Phone: 859.586.0600

                                September 8, 2005

Securities and Exchange Commission
Attention: Brad Skinner, Accounting Branch Chief
100 F. Street, N.E.
Washington, DC 20549

     Re:  Pomeroy IT Solutions, Inc.
          File No. 000-20022

Dear Mr. Skinner:

     Pomeroy  IT  Solutions,  Inc.,  a  Delaware  corporation  (the "Company" or
"Pomeroy"), hereby submits the responses set forth below to your Comment Letter,
dated August 24, 2005 (the "Comment Letter"), pertaining to the Company's Annual
Report  on  Form 10-K for the year ended January 5, 2005, as amended in the Form
10-K/A  filed May 5, 2005, and the Quarterly Report on Form 10-Q for the quarter
ended  July  5,  2005.

     The  responses  set  forth below correspond to the numbered comments in the
Comment  Letter.  For  your  convenience, we have included your original comment
from  the  Comment  Letter  followed  by  the  Company's  response.

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

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Securities and Exchange Commission
September 8, 2005
Page 2

     THAT  AFFECT  OPERATING  CASH  FLOWS. PLEASE TELL US HOW YOU CONSIDERED THE
     GUIDANCE  IN  SECTION  IV.B.1  OF  SEC  RELEASE  33-8350.

     Historically,  the  Company's  operating  cash  flow has been a function of
typical  business  factors which the Company had not determined to be underlying
drivers,  such  as an increase or decline in business, decisions to utilize cash
to  obtain  cash  discounts associated with the Company's trade accounts payable
and certain floor plan arrangements, and decisions on whether to finance product
purchases  through  the  Company's  floor  plan  arrangements  or  through other
arrangements with vendors that may be available from time to time. Specifically,
operating  cash  flow  had  been high during fiscal 2002 and 2003 primarily as a
result  of  a  decline  in  business  during  those  years.  Operating cash flow
decreased  in  fiscal  2004  as a result of a number of factors, specifically, a
growth  in business, a decision to aggressively pursue cash discounts related to
accounts  payable  and  certain  floor plan arrangements, and the acquisition of
Alternative Resources Corporation ("ARC"). In particular, in connection with the
ARC  acquisition,  late  in  2004,  the  Company  eliminated  an  ARC  factoring
arrangement  with  a  financial  institution, related to a specific customer. By
eliminating  this  arrangement,  the  collection  on  these specific receivables
changed  from  credit  terms of Net 10 to Net 45. During the conversion of these
credit  terms,  Pomeroy  experienced  a  decrease of approximately $7 million in
operating  cash  flows.

     With  the  completion  of  the  ARC  acquisition  and  recently  announced
developments  relating  to  the provision of services, on a going forward basis,
Pomeroy  anticipates  both  a growth in its services business and an increase in
the  overall proportion of services revenue to total revenue. The acquisition of
ARC  has  significantly  expanded Pomeroy's information technology solutions and
staffing  services,  including  Help  Desk,  Desktop  Support  and  Technology
Deployment Service offerings, and added approximately 1,500 technical employees.
As  a result, Pomeroy has determined that an underlying driver of operating cash
flows  in accordance with Section IV.B.1 of SEC Release 33-8350 is a significant
growth  or  decline in service revenue combined with a significant change in the
proportion  of  services  revenue  to  total  revenue.

     In Pomeroy's MD&A discussions in future SEC filings, the Company intends to
disclose  that  a  growth  or  decline in services revenue in conjunction with a
change  in  the proportion of services revenue to total revenue is an underlying
driver  of  operating  cash flows. The following disclosure will be added to the
Company's  MD&A:

     The  amount  of cash derived from operating activities will vary based
     on  a  number  of business factors which may change from time to time,
     including  terms of available financing from vendors, downturns in the
     Company's business and/or downturns in the businesses of the Company's
     customers.  However,  a  growth  or  decline  in  services  revenue in
     conjunction  with  a  change  in the proportion of services revenue to
     total  revenue  is  an underlying driver of operating cash flow during
     the  period  of  growth  because  a  majority of the Company's service
     revenue  is  generated  based  upon  the  billings  of  the  Company's
     technicians. The cash outlay for these labor/payroll costs is incurred
     bi-weekly  with  each  pay  period.  The  invoicing for the service is

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Securities and Exchange Commission
September 8, 2005
Page 3
     generated  on various billing cycles as dictated by the customers, and
     the  respective  cash inflow typically follows within 30 to 60 days of
     invoice date, which may be as long as 60 to 120 days from the time the
     services  are performed. This differs from product revenue in that the
     time  period  between  the  time  that  the Company incurs the cost to
     purchase  the  products  and collects the revenue from its customer is
     typically  shorter,  usually  from  0  to  60  days,  and  the Company
     primarily  orders  inventory  for  a  particular  customer rather than
     stocking  large  amounts  of  inventory.  The  Company  anticipates an
     increase  in  service revenue and in the proportion of service revenue
     to  total  revenue  which,  if  it occurs, may result in a significant
     decrease  in  cash  flows  from operating activities during periods of
     significant  growth  or  periods  of  excess  technical  capacity.

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.

     At  the time of closing the books for the fiscal year ended January 5, 2005
("fiscal  2004")  and the audit of the Company's financial statements for fiscal
2004  by  the  independent  auditors  for  the Company, both the Company and its
auditors  were aware of particular deficiencies in internal controls relating to
service  revenue  recognition  and  to  other system reporting functions. In the
preparation  of  the  Company's  financial  statements  for fiscal 2004, and the
independent  audit  of  those financial statements, the Company and its external
auditors  each  utilized  mitigating  procedures  including  the  performance of
additional  manual  processes,  extended  cut-off  procedures  and  testing  of
financial activity subsequent to year end to verify and supplement the financial
information  derived  from  the  Company's systems. Accordingly, the Company and

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Securities and Exchange Commission
September 8, 2005
Page 4

its external auditors each concluded that the disclosure controls and procedures
used  in  preparing  and  auditing  the financial statements for the fiscal year
ended  January  5, 2005 were effective and the Company's chief executive officer
and  chief  financial  officer were able to provide the required certifications.
Likewise,  our  independent auditors considered these identified deficiencies in
internal  control  in  determining  the  nature,  extent  and  timing  of  audit
procedures  performed  in  support of their opinion on the Company's fiscal 2004
financial  statements, as set forth in the sixth paragraph of their report dated
May  3,  2005  included  in  the  Company's  Form  10-K/A  filed on May 5, 2005.

     Management's testing and assessment of its internal controls over financial
reporting   in   accordance   with   the   requirements  under  Section  404  of
Sarbanes-Oxley  was not completed until after the filing of its Annual Report on
Form  10-K  on April 5, 2005, and in a few cases, some deficiencies of which the
Company  was aware recurred, causing the Company to ascribe greater significance
to  such deficiencies. During the last week of April, 2005, management concluded
that  the  deficiencies  relating  to its internal controls over the accuracy of
service billing calculations and revenue recognition related to service activity
could  result (but had not resulted) in a material misstatement of its financial
statements  and,  therefore, constituted a material weakness. Later in that same
week,  management  concluded that the combination of approximately 15 individual
control  deficiencies  related  to  the  financial  reporting  function,  in the
aggregate, could result (but had not resulted) in a material misstatement of its
financial  statements  and  further determined that due to that possibility, the
aggregate of such deficiencies constituted a second material weakness.

     Pomeroy  had  not  identified  a material weakness before the filing of its
Annual  Report  on Form 10-K; thus condition (D) of SEC Release 34-50754 was not
applicable.  In  summary, while Pomeroy was aware of specific deficiencies as of
the  filing  of the Form 10-K on April 5, 2005, it had not completed its testing
and  assessment  of  those  deficiencies  to conclude that there was one or more
material weaknesses.

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.

     For  fiscal  2004,  the  Company's sales of computer hardware, software and
related  products  were  approximately  $545.1 million, or 73.4% of consolidated
revenue.   The portion of those sales that comprised software approximated $50.9
million,  or  6.9%  of  consolidated  revenue.

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Securities and Exchange Commission
September 8, 2005
Page 5

     Pomeroy does not develop, own or sell proprietary software. At the point of
sale, Pomeroy is not responsible for constructing, maintaining or correcting any
third  party  software  application. The Company is also not legally responsible
for correcting third party software program code errors for our customers either
under  warranty  obligations  or  in  non-warranty  situations.

     Pomeroy  fulfills  customer orders for third party "off-the-shelf" software
products.  Pomeroy's  invoice  price to the customer reflects a cost-plus markup
based on the distributor's or vendor's price to Pomeroy. Examples of third party
software  products  that  Pomeroy  purchases  and  resells  include, but are not
limited  to,  Microsoft,  Oracle, VM Wear, Veritas, McAfee and Novell. Pomeroy's
offerings  to  its customers also include Pomeroy purchasing the "off-the-shelf"
software  from  a  vendor, installing it on the computer equipment and invoicing
the  customer for both the hardware equipment and software product(s) separately
and  with  a cost-plus markup. In both of these situations hardware and software
revenue  is  recognized  upon  shipment.

     Pomeroy's revenue recognition policy is consistent with the requirements of
Staff  Accounting  Bulletin No. 101 (SAB 101), "Revenue Recognition in Financial
Statements,"  and  Statement  of  Position  97-2  (SOP  97-2), "Software Revenue
Recognition."   Pomeroy  records revenue when it is realized or earned.  Pomeroy
considered  the  four  criteria  below  since  "the arrangement does not require
significant  production,  modification  or  customization  of  software":
          -    Persuasive evidence of an arrangement exists (earned);
          -    Delivery has occurred (earned);
          -    The vendor's price is fixed or determinable (realizable); and
          -    Collection from our customer is probable. (realizable).

     In cases where it was concluded that software was incidental to the product
sale  as  a  whole,  Pomeroy has considered SOP 97-2, paragraph .02, to properly
recognize  revenue.  This  conclusion  is  based  on  the  following  criteria:
          -    The  reselling  of  third party software and software licenses is
               not  the  primary  marketing  or  selling  focus  of  Pomeroy;
          -    The  software vendor provides post-contract customer support, not
               Pomeroy;  and
          -    The software vendor incurs all costs, not Pomeroy.

Pomeroy's  third  party  software  arrangements  may  be  involved  with  other
multi-element  arrangements. These arrangements and our accounting treatment are
discussed  in  our  Revenue  Recognition  response  to  item  #8.

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.

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Securities and Exchange Commission
September 8, 2005
Page 6

     Pomeroy  is  a  reseller  of  a  broad range of IT products from its vendor
partners  tha