SecProbe.io

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Mail Stop 4651
								August 3, 2005

Bonnie J. Roe, Esq.
Day, Berry & Howard LLP
875 Third Avenue
New York, NY 10022

 	Re:    	Globix Corp.
		Preliminary Schedule 14A
      Filed on July 11, 2005
		File No. 1-14168

Dear Ms. Roe:

      We have limited our review of your filing to matters
relating
to proposal three, specifically the parameters of the
authorization
being sought. Based on this limited review, 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.  Below, 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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

   Proposal Three:  Authorization of the Issuance of Additional
Shares of Common Stock
1. While you indicate the maximum amount of shares that may be
issued
in connection with the three transactions described under the
proposal, we note that you have not provided information with
regard
to the range of terms within which you would negotiate the
transactions.  For example, will the authorization sought in this
proposal expire after a predetermined period or continue
indefinitely?  Is there a minimum price below which you will not
issue shares in order to effect an exchange offer?  Is there a
minimum price below which you will not negotiate private
placements
if the stock is issued at below market prices?  The terms least
favorable to shareholders should be fully described to the extent
known.  Please revise (a) to provide a time limit for the
authorization, or affirmatively state that the authorization has
no
limits, and (b) to define the parameters within which the
transaction
types could be negotiated.
2. We note your statement that you are not "currently
contemplating
any specific transaction" of the types described.  Please revise
to
state, if true, that you have no current plans, commitments or
arrangements to enter into any such transactions.  For example,
have
you entered into any negotiations, received a letter of intent, or
otherwise initiated the process of identifying and acquiring a
"business opportunity"?  To the extent that you taken any such
steps,
even if a "specific transaction" has not been identified, those
steps
should be described in the proxy statement.

      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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging 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.

      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 our review of your filing or in
response to our comments on your filing.

      Please address all comments to Maryse Mills-Apenteng at 202-
551-3457 or, in her absence, to the undersigned at 202-551-3462.
If
you still require further assistance, you may contact Barbara C.
Jacobs, Assistant Director at 202-551-3730.

								Sincerely,

								Mark P. Shuman
								Branch Chief - Legal

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Bonnie J. Roe, Esq.
Day, Berry & Howard LLP
August 3, 2005
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