SecProbe.io

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      May 23, 2005

Mail Stop 4561

	VIA U.S. MAIL AND FAX (231) 561-7224

Mr. Kenneth S. Cragun
Interim Chief Financial Officer
FindWhat.com, Inc.
5220 Summerlin Commons Boulevard, Suite 500
Fort Myers, FL 33907

Re:	FindWhat.com, Inc.
	Form 10-K/A for the year ended December 31, 2004
	File No. 000-34028

Dear Mr. Cragun:

      We have reviewed your above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.

      In our comments, we 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 10-K for the year ended December 31, 2004

Financial Statements and Notes

Consolidated Statements of Operations, page F-7
1. We note the line items captioned "Search serving" and
"Marketing,
sales and service".  In a supplemental response please clarify
whether the latter caption includes cost of services and if so,
present your cost of services separately in future filings in
accordance with Rule 5-03 of Regulation S-X.

Note C - Mergers and Acquisitions, pages F-16 to F-20
2. We note from the unaudited pro forma condensed consolidated
balance sheets included in the current reports filed on form 8-K/A
for Comet and Espotting that these acquirees had deferred revenue
balances.  In a supplemental response, please tell us the nature
of
the deferred revenue and how you applied EITF 01-3 Accounting in a
Business Combination for Deferred Revenue of an Acquiree in your
purchase accounting for each of your acquisitions during the
period.

   Miva, page F-16 to F-17
3. We note the fifteen-year amortization period for your customer
relationships.  In a supplemental response, please state whether
or
not the customer relationships are contractually based, and if so,
the period and cancellation terms.  Additionally, please explain
how
you considered straight-line amortization as opposed to another
methodology for the contribution to future cash flows, and how you
considered the impact of lower than expected operating performance
that resulted in the goodwill impairment on the estimated useful
life
of the customer relationships.

   Espotting, pages F-19 to F-20
4. Please supplementally tell us if options and warrants issued to
Espotting employees and affiliates are vested or unvested.
Additionally, explain what future performance, if any, is required
by
the employees.

5. From your disclosure, we note that you acquired Espotting, to
gain
market share internationally.  It appears you would gain this
market
share through Espotting`s tradename, advertiser relationships, and
domain name; however you have assigned little or no value to these
assets.  Please supplementally advise us and disclose in future
filings, the primary reasons for the acquisition and factors that
contributed to a purchase price with significant amounts of
goodwill.
Please explain your methodology for allocating the purchase price
and
why you have not recorded any marketing-related intangible assets,
such as domain names, or contract-based intangible assets, such as
service agreements or lease agreements.  Refer to paragraphs 39
and
A14 of SFAS 141.  Additionally, please advise us of any intangible
assets included in goodwill that do not meet the criteria for
recognition apart from goodwill.

Note M - Geographical Information, page F-27
6. We note that you provide the information about geographic areas
required by SFAS 131, but do not include separate disclosure about
products and services required by the Standard.  In future
filings,
please include the required disclosure or provide a supplemental
response and indicate in future filings why the information is
impracticable to provide.

Note P - Stock Incentive Plans, pages F-30 to F-33
7. In a supplemental response, please provide a reconciliation of
the
$3,309,000 charged to APIC and 1,073,000 shares of common stock
issued reflected on the statement of stockholders` equity relative
to
the options and warrants exercised and their exercise price
reflected
in the footnote.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please file your response on EDGAR.

	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.

	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 filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Matthew Dowling, Staff Accountant, at (202)
551-3467 or me at (202) 551-3403 if you have questions.

						Sincerely,

Steven Jacobs
						Accounting Branch Chief

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FindWhat.com, Inc.
May 23, 2005
Page 1 of 3

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