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CORRESP
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      Globix Correspondence

              Day,
                Berry & Howard LLP

COUNSELLORS
                AT LAW

              Bonnie
                J. Roe

              Direct
                Dial: (212) 829-3605

              E-mail:
                bjroe@dbh.com

              August
                31, 2005

    Securities
      and Exchange Commission

    Division
      of Corporation Finance

    100
      F
      Street, NE

    Washington,
      DC 20549

    Attention:
      Maryse Mills-Apenteng

                Re:

                Globix
                  Corporation

                Preliminary
                  Schedule 14A

                Filed
                  on July 11, 2005

                File
                  No. 1-14168

    Dear
      Ms.
      Mills-Apenteng:

    On
      behalf
      of Globix Corporation, a Delaware corporation (the “Company” or “Globix”), we
      hereby submit for filing pursuant to Rule 14a-6(a) of Regulation 14A, a revised
      preliminary proxy statement. Globix filed an initial preliminary proxy statement
      on July 11, 2005.

    Set
      forth
      below are the Company’s responses to the comments given by the staff (the
“Staff”) of the Securities and Exchange Commission (the “SEC”) by letter dated
      August 3, 2005 with respect to the preliminary proxy statement.

    The
      following responses are keyed to the sequential numbering of the comments in
      the
      SEC letter.

    Proposal
      Three: Authorization of the Issuance of Additional Shares of Common
      Stock

    Comment
      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.

    Securities
      and Exchange Commission

    Page
      -2-

    August
      31, 2005

    Response
      1. The
      Company has revised the preliminary proxy statement in response to the comment.

    Comment
      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.

    Response
      2. As
      indicated in the revised preliminary proxy statement, the Company has no current
      plans, commitments or arrangements to enter into any such
      transactions.

    A
      separate letter from the Company containing the representations requested in
      your comment letter is being filed concurrently.

    Should
      you have any questions or comments with respect to the foregoing, please do
      not
      hesitate to contact the undersigned at (212) 829-3605 or Anna Hunnicutt at
      (617)
      345-4686.

            Very
              truly yours,

            /s/
              Bonnie J. Roe
Bonnie
              J. Roe

                cc:

                Mark
                  P. Shuman

                Securities
                  and Exchange Commission

                Peter
                  K. Stevenson

                Globix
                  Corporation

                Robert
                  M. Dennerlein

                Globix
                  Corporation

                James
                  C. Schroeder, Esq.

                Globix
                  Corporation