SecProbe.io

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						June 23, 2005

Room 4561

Peter K. Stevenson
President and Chief Executive Officer
Globix Corporation
139 Centre Street
New York, NY 10013

Re:	Globix Corporation
	Registration Statement on Form S-3
	Filed May 24, 2005
	File No. 333-125185

	Form 10-K for fiscal year ended September 30, 2005
Forms 10-Q for the fiscal quarters ended December 31, 2005 and
March
31, 2005
	File No. 1-14168

Dear Mr. Stevenson:

	This is to advise you that we conducted a review of your
disclosure provided in response to Items 307 and 308(c) of
Regulation
S-K, disclosure concerning your selling shareholders, and the
rights
granted to purchase additional shares contained in your Securities
Exchange Agreement.  Based on this limited review of the
referenced
filings, we have the following comments.  Where indicated, we
think
you should revise your documents in response to these comments.
If
you disagree, we will consider your explanation as to why our
comment
is inapplicable or a revision is unnecessary.  Please be as
detailed
as necessary in your explanation.  In some of our comments, we may
ask you to provide us with supplemental information so we may
better
understand your disclosure.  After reviewing this information, we
may
or may not 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form S-3

Selling Holders, page 17
1. Please tell us the exemption from the registration requirements
you relied upon with respect to the debt-for-equity exchange
transactions that were conditions of the Neon merger.  Tell us
whether you believe that the requirements of Section 3(a)(9) were
satisfied with respect to that exchange.
2. Please tell us the exemption you rely upon with respect to the
offer and any sale of the shares that exchanging debt holders
would
have the right to acquire at $2.75 per share, if the registration
statement for the shares issued in the exchange offer is not
effective within 120 days after the Neon merger, or if the
registration statement is not effective for more than ninety days
in
the aggregate during the first twelve months.  Please expand the
prospectus to clarify that the shares that might be issued
pursuant
to this arrangement are not being registered for resale in this
registration statement.
3. We note disclosure for example, under footnote 3 and 10 to the
selling holder table, that certain selling stockholders may be
affiliates of broker-dealers.  Please revise to identify
unambiguously selling stockholders that are affiliates of broker-
dealers.
4. In your cover letter you advise that none of the selling
stockholders received their shares as compensation.  We further
note
that Loeb Partners and Goldman Sachs are registered broker-
dealers.
In your response letter, please describe how those registered
broker-
dealers acquired their shares.  Unless a registered broker-dealer
that is a selling stockholder acquired its shares as transaction-
based compensation for investment banking services, it should be
named as an underwriter.  It appears you should revise to state
that
Loeb Partners and Goldman Sachs are underwriters.

Plan of Distribution, page 21

Form 10-Q for the quarter ended March 31, 2005

Controls and Procedures, page 24
5. It appears there may have been changes in your internal
controls
over financial reporting during the relevant period.  See Item
308(c)
of Regulation S-K.  Please advise us in this respect.  See also
Q.5
of Management`s Report on Internal Control Over Financial
Reporting
and Certification of Disclosure in Exchange Act Periodic Reports,
Frequently Asked Questions, as revised October 6, 2004.
6. Please revise to describe the events surrounding your
reclassification of expenses including all material remedial
actions.
Please include dates of corrective actions, if available and any
material costs associated therewith.  Please provide the same
information for your process of integrating Neon.  Finally, advise
as
to future actions that will be taken that may have an material
effect
on internal controls pursuant to your reclassification and your
integration of Neon.

Form 10-Q for the quarter ended December 31, 2004

Controls and Procedures, page 17
7. We note disclosure in your Form 10-K that your disclosure
controls
and procedures were ineffective as of September 30, 2004.  Stating
that you reclassified payroll and occupancy costs, does not
identify
the deficiencies in your disclosure controls and procedures, nor
does
it explain what you did to address the deficiencies in the
disclosure
controls and procedures or why you conclude that the steps taken
addressed the inadequacies.
8. You refer to reclassification of payroll and occupancy expenses
as
part of the disclosure provided pursuant to Item 308(c).  It is
unclear what, if any, changes in internal controls over financial
reporting were implemented in connection with the
reclassifications.
Additionally, as the reclassifications occurred in February, 2005
it
is unclear whether any changes in internal controls over financial
reporting took place in the quarter ended December 31, 2004.
Changes
in your financial statements do not appear to be changes in
internal
controls over financial reporting.  Please advise.

      As appropriate, please amend your filings in response to
these
comments.  With respect to the comments on the referenced periodic
reports your response should be provided as soon as possible and
not
later than July 9, 2005.  You may wish to provide us with marked
copies of the amendments to expedite our review.  Please furnish a
cover letter with your amendments that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendments and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert staff comments and the declaration of
effectiveness 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 connection with our review of
your
filing or in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities
specified in the above registration statement.  We will act on the
request and, pursuant to delegated authority, grant acceleration
of
the effective date.

	We direct your attention to Rule 461 regarding requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

	If you have any questions, please call Adam Halper, at (202)
551-3482.  If you require additional assistance you may contact
me,
at (202) 551-3462 or in my absence Barbara C. Jacobs, Assistant
Director at, (202) 551-3730.

							Sincerely,

							Mark P. Shuman
							Branch Chief - Legal

cc: 	Bonnie J. Roe
	Day, Berry & Howard LLP
	875 Third Avenue
	New York, NY 10022
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Peter K. Stevenson
June 23, 2005
Globix Corporation
Page 5

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