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pomeroy
IT Solutions

                                                  1020 Petersburg Road
                                                  Hebron, KY  41048
                                                  Phone:  859.586.0600

                                December 29, 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  additional  responses set forth below to your
follow-up  Comment  Letter,  dated  November  22,  2005  (the "Comment Letter"),
pertaining  to  the  Company's  Annual  Report  on  Form 10-K for the year ended
January 5, 2005 and the Quarterly Report on Form 10-Q for the quarter ended July
5,  2005. The Company appreciates that the Commission's comments are designed to
assist  the  Company  in  providing more meaningful disclosure to the investment
community  and to clarify certain of the Company's revenue recognition policies.

     Our  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
------------------------------------------------------------

FINANCIAL  STATEMENTS
---------------------

NOTE  2.  SUMMARY  OF  SIGNIFICANT  ACCOUNTING  POLICIES
--------------------------------------------------------

REVENUE  RECOGNITION,  PAGE  F-9
--------------------------------

1.   WE  HAVE  READ YOUR RESPONSE TO PRIOR COMMENT NUMBER 3 AND IT IS UNCLEAR TO
     US  HOW YOU HAVE DETERMINED THAT THE RISKS OF OWNERSHIP HAVE PASSED TO YOUR
     CUSTOMERS  IN  ORDER TO RECOGNIZE REVENUE ON A BILL AND HOLD BASIS. IN THIS
     REGARD, PLEASE EXPLAIN TO US HOW YOU HAVE EVALUATED THE EFFECT OF SECTION 5
     OF  YOUR  COI  AGREEMENT.  THIS  SECTION

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Securities and Exchange Commission
December 29, 2005
Page 2

     APPEARS  TO  INDICATE  THAT  YOU  ARE  RESPONSIBLE FOR MAINTAINING PROPERTY
     INSURANCE AND THAT RISK OF LOSS SHIFTS TO YOUR CUSTOMERS UPON DELIVERY TO A
     COMMON  CARRIER.

     The  Company's  logistical  deployment  service  program  is  utilized  by
customers  who  are implementing a staged computer migration or a large computer
refresh  project.  The  customer's  business  purpose  for doing so is to ensure
consistency  and  standardization  in  product  specifications  throughout  the
customer's  facilities.  Due  to  ever-changing  technology,  original equipment
manufacturers  will  not  guarantee  consistency  and standardization in product
specifications. Therefore, a bulk purchase is made at the customer's request, in
order to ensure that the respective customer's business requirements are met and
that  consistent,  standardized  products  are deployed across the customer's IT
environment.  Customers  request  Pomeroy  to perform staged deliveries to their
various  locations,  normally during a six-month period, because it is generally
not  feasible  to  install  all  of  the  computers  simultaneously.

     There  are  a  number of factors that affect whether the risks of ownership
have  passed  to  the  customer.  The agreement pertaining to the Customer Owned
Inventory  ("COI")  clearly  provides that legal title remains with the customer
while at a Pomeroy facility. The customer assumes all risk of ownership and risk
of  loss  for computer hardware obsolescence, defects, theft and damage while in
the  physical  possession  of  Pomeroy. In addition, the customer's products are
subject to the original manufacturer's warranty terms from the date of purchase.

     Customer-owned inventories are segregated from Pomeroy-owned inventory. Due
to  the  practical  difficulties  of  each customer obtaining separate insurance
coverage,  Pomeroy's  general  insurance  policy also provides replacement value
coverage  for  all  customer-owned inventories. This fact is not indicative that
risk  of loss is with Pomeroy since any proceeds from an insurance claim arising
from  such  loss  belong  to  the  customer  and to the extent that the original
purchase  price is greater than the replacement value (the insurable amount) the
customer  would  be  liable  for  this  loss.

     For  these reasons, Pomeroy has concluded that risk of ownership has passed
to  our  customers.

2.   PLEASE  EXPLAIN  TO  US  HOW  YOU  HAVE CONSIDERED FOOTNOTE 18 TO SAB TOPIC
     13(A)(3)(A)  REGARDING  THE  FORM  OF CUSTOMER REQUESTS RELATED TO BILL AND
     HOLD  TRANSACTIONS.

     The  nature  of  Pomeroy's  bill  and  hold  transactions  is such that the
customer  requests  Pomeroy to hold its products until such time as the products
are  deployed  to  the customer's sites. The Company's COI contractual agreement
specifically  states  the  customer  desires  Pomeroy  to  acquire  products for
storage,  configuration  and/or  deployment. The customer's business purpose for
doing  so is to ensure consistency and standardization in product specifications
throughout  the customer's facilities. Due to ever-changing technology, original
equipment  manufacturers  will  not guarantee consistency and standardization in
product  specifications.  Therefore,  a bulk purchase is made by the Company, at
the  customer's  request,  in  order  to  ensure  that the respective customer's
business  requirements  are  met  and that consistent, standardized products are
deployed  across  the  customer's IT environment with a staged, phased approach.

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Securities and Exchange Commission
December 29, 2005
Page 3

     Pomeroy  requires  a  written, customer-signed document outlining the terms
and  conditions,  prior  to  recording  any  revenue  under  a  bill  and  hold
arrangement.  Therefore,  we have addressed footnote 18 to SAB Topic 13(A)(3)(a)
by  requiring  a  written,  signed  customer  request.

3.   YOUR  RESPONSE TO PRIOR COMMENT NUMBER 3 DOES NOT APPEAR TO INDICATE THAT A
     STATED,  FIXED  DELIVERY SCHEDULE EXISTS IN ORDER TO RECOGNIZE REVENUE ON A
     BILL  AND  HOLD  BASIS.  PLEASE  EXPLAIN  FURTHER  HOW  YOU  HAVE  MET THIS
     REQUIREMENT.

     A  roll-out  schedule  for  product deployment is part of a staged computer
migration or a large computer refresh project. This schedule, which is typically
a  part  of  a  statement of work between Pomeroy and the customer, is important
because  it  requires  significant coordinating efforts between the customer and
the  Company.  Through  a  Master  Agreement,  COI Agreement or separate written
documents,  the  customer  directs,  in  writing, the timing and location of the
delivery  of  their  computer  products.  However,  the COI Agreement (or Master
Agreement  if  the  terms  relating  to  COI  are  incorporated  into the Master
Agreement)  provides  that  if  the customer fails to direct the delivery of the
products  within 180 days, then Pomeroy is authorized to ship the product to the
customer's  place  of  business  at  the  end  of  the  180-day  period.

4.   PLEASE  ASK  THAT  YOUR  AUDITORS  DESCRIBE TO US THE AUDIT PROCEDURES THEY
     APPLIED  TO  BILL  AND  HOLD TRANSACTIONS AND THE EVIDENCE THEY GATHERED TO
     SUPPORT  THEIR CONCLUSION THAT REVENUE MAY BE RECOGNIZED PRIOR TO SHIPMENT.
     REQUEST  THAT THEY SPECIFICALLY EXPLAIN HOW THEY ADDRESSED THE REQUIREMENTS
     IDENTIFIED  IN  THE  COMMENTS  ABOVE.

     Our  auditors,  Crowe  Chizek  and Company LLC ("Crowe Chizek" or "they" or
"their")  received from Pomeroy a listing by customer, by invoice of COI held by
Pomeroy  as  of  January  5,  2005.  They  compared average gross margins of COI
hardware  sales  year  over  year  noting  consistency  in the current year with
average gross margins realized in the previous year. They selected the largest 5
customer  balances  for  detail testing and confirmation (the largest 5 customer
balances  represented  72%  of  the  total COI balance at January 5, 2005). They
requested  confirmations  from  the  customers  of  the detail of the customers'
inventory  that  Pomeroy  was  holding  on their behalf.They received confirming
responses  from 4 of the 5customersrepresenting 85% of thetotal amountconfirmed.
The  fifth  customer  did not respond.For each of the 5 selected customers, they
reviewed  a copy of the contract/ agreement between the customer and Pomeroy and
a  sample  of  invoices  included  in  the  confirmation  letters,  representing
inventory held by Pomeroy at year end.

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Securities and Exchange Commission
December 29, 2005
Page 4

     Crowe  Chizek's  assessment and review concluded with an inquiry of Pomeroy
management  of  the following seven criteria points, set forth by the Commission
in  SAB  No.  101, to be met in order to recognize revenue when delivery has not
occurred.  Their  assessment of Pomeroy's COI revenue recognition concluded that
such requirements, as set forth below, were met:

     -    The  risks  of  ownership  must  have  passed  to  the  buyer;
     -    The  customer  must  have  made  a  fixed  commitment  to purchase the
          goods,preferably  in  written  documentation;
     -    The buyer,  not  the seller, must request that the transaction be on a
          bill and hold basis. The buyermust have a substantial business purpose
          for  ordering  the  goods  on  a  bill  and  hold  basis;
     -    There  must  be  a  fixed  schedule  for  delivery  of  the goods. The
          date  for  delivery must be reasonable and must be consistent with the
          buyer's  business  purpose (e.g., storage periods are customary in the
          industry);
     -    The  seller  must  not  have  retained  any  specific  performance
          obligations such that the earning process is not complete;
     -    The  ordered  goods  must  have  been  segregated  from  the  seller's
          inventory and not be subject to being used to fill other orders and
     -    The equipment (product)  must  be  complete  and  ready  for shipment.

     As  part  of  their  year-end  physical inventory observation, Crowe Chizek
noted that the Company's COI is separately identifiable from Pomeroy's inventory
(containing  unique yellow bar code stickers) and is given an immaterial 1-penny
value on the priced out inventory listing for identification purposes.

     Crowe  Chizek  inquired of Pomeroy management of any additional unique bill
and  hold  arrangements  that existed at year end beyond the COI items reviewed.
Pomeroy  management  advised  them that no other such arrangements existed as of
January 5, 2005.

     Specifically to comments 1 through 3 raised by the Commission in its letter
to  Pomeroy dated November 22, 2005, Crowe Chizek concurred with the response by
Pomeroy management and through review of the documentation mentioned above, that
risk  of  ownership  had transferred to the customer and is acommon practice for
logistical  deployment  in  this  industry.  The fact that the Company maintains
property  insurance  for  the convenience of its customers does not override the
assessment  that  ownership  rights  have  transferred. They determined that the
signed  COI  contracts  (or  equivalent documentation) between each customer and
Pomeroy  represented  the  written  mutual  agreement  between  the parties that
Pomeroy  was  holding  the  customer's inventory on its behalf.The typical fixed
delivery  schedule  as  detailed  in the contract required the purchaser to take
possession  of the inventory within 180 days or be subject to additional storage
fees.

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Securities and Exchange Commission
December 29, 2005
Page 5

FORM  10-Q  FOR  FISCAL  QUARTER  ENDED  JULY  5,  2005
-------------------------------------------------------

ITEM  4.  CONTROLS  AND  PROCEDURES,  PAGE  20
----------------------------------------------

5.   WE  HAVE  READ  YOUR  PROPOSED  DISCLOSURE  PROVIDED  IN  RESPONSE TO PRIOR
     COMMENT  NUMBER  6. IF YOU CONTINUE TO DESCRIBE THIS REVIEW, PLEASE PROVIDE
     THE FOLLOWING DISCLOSURES:

     -    EXPLAIN  HOW  "SUFFICIENT" SHOULD BE INTERPRETED BY READERS AND DEFINE
          THE  "INTERNAL  CONTROL  STANDPOINT"  FROM  WHICH  THE  EVALUATION WAS
          PERFORMED;

     -    CLEARLY  EXPLAIN HOW THIS EVALUATION AND THE RELATED CONCLUSION DIFFER
          FROM  THOSE  DESCRIBED  IN  ITEMS  307  AND 308 OF REGULATION S-K; AND

     -    IDENTIFY  THE  CONSULTING FIRM AND PROVIDE A SUMMARY OF THEIR RELEVANT
          QUALIFICATIONS.

     Pomeroy  proposes  to  further  revise its Form 10-Q for the fiscal quarter
ended  July  5,  2005  by removing the disclosure of the review performed by the
third  party  consulting  firm  contained  in  Item 4 - Controls and Procedures,
Changes  in  Internal  Controls  over  Financial Reporting. The Company does not
believe  it  is  necessary to include the disclosure because the consulting firm
performed  an  assessment  over  our service revenue manual control processes to
determine  whether there were any deficiencies and to make recommendations as to
how  the  processes  could  be  improved.  We  are submitting, as Exhibit A, the
Company's proposed revised disclosure (which still includes the revisions to the
third  paragraph  that were proposed by the Company in its letter dated November
1, 2005). We are also including a marked copy of this additional proposed change
as  Exhibit  B.

     Thank  you for your comments. If you have any questions, please contact our
counsel,  Elizabeth  A. Horwitz at (513) 852-8207, or me at (859) 586-0600, ext.
1416.

                                        Sincerely,

                                        /s/  Stephen  E.  Pomeroy,  CEO
                                        ---  --------------------------
                                        Stephen  E.  Pomeroy
                                        Chief  Executive  Officer

cc:  Elizabeth  A.  Horwitz, Esq., Cors & Bassett, LLC
     Frank Criniti, Crowe Chizek and Company LLC

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Securities and Exchange Commission
December 29, 2005
Page 6

                                                                        EXHIBITA
                                                                        --------
[FORM  10-Q  FOR  FISCAL  QUARTER  ENDED  JULY  5,  2005]

ITEM 4-CONTROLS AND PROCEDURES

EVALUATION  OF  DISCLOSURE  CONTROLS  AND  PROCEDURES

The  Company  maintains  disclosure controls and procedures (as defined in Rules
13(a)-15(e)  and  15(d)-15(e) of the Securities Exchange Act of 1934, as amended
(the  "Exchange  Act"))  designed  to  provide  reasonable  assurance  that  the
information  required  to  be  reported in its Exchange Act filings is recorded,
processed,  summarized  and  reported  within  the  time  periods  specified and
pursuant to the regulations of the Securities and Exchange Commission, including
controls  and procedures designed to ensure that this information is accumulated
and  communicated  to  the  Company's  management, including its Chief Executive
Officer  and  Chief Financial Officer, as appropriate, to allow timely decisions
regarding  required  disclosure.  It  should  be noted that, because of inherent
limitations,  the  Company's  disclosure  controls  and procedures, however well
designed  and operated, can provide only reasonable, and not absolute, assurance
that  the  objectives  of  the  disclosure  controls  and  procedures  are  met.

As more fully described in Item 9A of the Company's Annual Report on Form 10-K/A
for  the  year  ended  January  5, 2005, the Company reported that it identified
material  weaknesses in its internal control over financial report