SecProbe.io

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Room 4561

      October 20, 2005

Mr. Randall D. Miles
Chairman and Chief Executive Officer
Lion, Inc.
4700 42nd Avenue SW, Suite 430
Seattle, WA 98116

      Re:	Lion, Inc.
   Form 10-KSB for the Fiscal Year Ended
   December 31, 2004
Filed March 31, 2005
   File No. 000-25159

Dear Mr. Miles:

      We have reviewed your response to our prior comment letter
dated July 8, 2005 in connection with our review of the above
referenced filing and have the following comments.  Please note
that
we have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your document. 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.

Management`s Discussion and Analysis

Business Enterprise Segments, page 12

1. Please refer to comment 1 in our letter dated July 8, 2005.  We
have reviewed your response and it remains unclear whether your
Leads, Loans and Capital Markets segments have met the aggregation
criteria under paragraph 17 of SFAS 131, in particular, the
requirement that the operating segments have similar economic
characteristics.  Please provide us a copy of the operating
results
that are regularly reviewed by your chief operating decision maker
to
make decisions about resource allocation and performance
assessment.

2. Your response indicates that while you track revenues by
product
group, your reporting system does not break out and report on
expenses by the same product groups.  Clarify whether you track
expenses within your groups (i.e., Leads, Loans and Capital
Markets).
If not, explain why you believe these represent operating segments
under paragraph 10 of SFAS 131 as it does not appear that your
CODM
regularly reviews operating results.

3. In future filings, provide the disclosures required by
paragraph
37 of SFAS 131 for your products.

Critical Accounting Policies, page 21

4. Please refer to comment 2 in our letter dated July 8, 2005.
Note
that we consider an amendment to your Form 10-KSB a subsequent
filing.  In this regard, if you amend your Form 10-KSB, you must
include the revision noted in your response to our prior comment
2.

Report of Independent Registered Public Accounting Firm, page 25

5. Please refer to comment 3 in our letter dated July 8, 2005.  We
have reviewed your response and note that the accountant`s report
currently included in your 10-KSB for the year ended December 31,
2004 does not comply with Article 2.02 of Regulation S-X as the
signature was inadvertently omitted from the EDGAR filing.  Please
amend your 10-KSB to include a signed report from your independent
accounting firm.

Note A - Summary Of Accounting Policies

Revenue Recognition, page 20

6. Please refer to comment 4 in our letter dated July 8, 2005.  We
note in your response that in certain instances you recognize
revenue
related to set-up fees for websites as they are developed due to
the
fact that these websites become the intellectual property of the
customer and the customer could host the website with another
vendor.
Tell us why you believe the development of the websites under
these
circumstances represents a separate earnings process.  In this
regard, please address the following:

* Is the functionality of the on-going service affected by the
timing
of the website development (i.e. does it coincide with the hosting
service);
* Have you provided website development to customers where you do
not
provide hosting services; and
* Have you provided hosting services to customers that used other
vendor`s services for developing a customer`s website or where
customers developed their own website.

      Please advise.

7. Please refer to comment 6 in our letter dated July 8, 2005.
Help
us better understand how you have established vendor specific
objective evidence (VSOE) for your maintenance related to the sale
of
your Pipeline Tool software. Your response indicates that VSOE of
your maintenance is consistent with your pricing structure for
similar maintenance.  Clarify what is meant by "similar
maintenance"
including how you have determined the pricing structure for
maintenance related to your software sales and how that complies
with
paragraph 10 and 57 of SOP 97-2.  In this regard, tell us whether
you
have had separate sales of your maintenance (i.e. maintenance
renewals) or if it has historically been sold together with the
license.  Clarify the initial period of PCS and whether you have
experienced renewals following the initial PCS period.  Please
advise.

Note B - Business Combination, page 35

8. Please refer to comment 9 in our letter dated July 8, 2005.  We
note in your response here, as well as your response to comment 5
in
our letter dated July 8, 2005, that the deferred revenue recorded
as
a result of the acquisition of Ignition Mortgage Technology
Solutions, Inc. relates to two term licensing arrangements to a
customer that included only the licensing component associated
with
the arrangement.  We also note that the customer has taken
delivery
of the software.  Based on your response, it does not appear that
you
have a legal obligation to provide additional goods or services to
this customer as required in EITF 01-3.  Help us understand what
remaining obligations you have to this customer related to this
arrangement to support your recording of $920,654 of deferred
revenue
related to this acquisition.

General

9. In connection with our prior comment letter dated July 8, 2005,
we
note that you provided, as previously requested, a statement in
writing that the company acknowledges 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.

However, be advised that a letter signed by counsel would not
satisfy
the requirement of this comment.  As a result, a representative
from
the Company should acknowledge, in writing, the above statements.

* * * * *

      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.

      You may contact Patrick Gilmore at (202) 551-3406, Lisa
Mitrovich, Assistant Chief Accountant, at (202) 551-3453 or me at
(202) 551-3730 if you have questions regarding comments on the
financial statements and related matters.

							Sincerely,

							Kathleen Collins
							Accounting Branch Chief

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Mr. Randall D. Miles
Lion, Inc.
October 20, 2005
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