SecProbe.io

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Mail Stop 0407

      							June 7, 2005

Mr. Horace J. Davis, III
Chief Executive Officer and Chief Financial Officer
Trinsic, Inc.
601 South Harbour Island Boulevard
Suite 220
Tampa, FL 33602

	Re:	Trinsic, Inc.
      Form 10-K for Fiscal Year Ended December 31, 2004
		Filed April 15, 2005

		Form 10-Q for Fiscal Quarter Ended March 31, 2005
		File No. 000-28467

Dear Mr. Davis:

      We have reviewed your filing and have the following
comments.
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 documents.  Please be as detailed as necessary in
your explanations.  In our comments we asked you to provide us
with
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 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 Fiscal Year Ended December 31, 2004

Note 2.  Summary of Significant Accounting Policies, page 59

Long-Lived Assets, page 59

1. In light of the December 15, 2004 decision by the FCC to limit
the
availability of unbundled network elements pursuant to section 251
of
the Telecommunications Act of 1996, it appears you should have
tested
your long-lived assets for recoverability pursuant to paragraph 8
of
SFAS 144.  Please explain to us management`s consideration of this
change in circumstance when complying with the guidance in SFAS
144.
If you did test your long-lived assets for impairment tell us when
and explain to us in detail why an impairment was not recognized.
If
you have not tested your long-lived assets for impairment explain
to
us why not.

Note 5. Property and Equipment, page 64

2. In the 2nd paragraph on page 10 of your 10-Q for the quarter
ended
March 31, 2005, you disclose that you reserved $2.5 million of the
promissory note from SipStorm, Inc. to reflect its estimated
realizable value.  Please tell us in your response letter the
change
in circumstances that occurred during the 1st quarter of 2005 that
caused you to reserve $2.5 million of this note.  In addition,
explain to us in detail how you originally accounted for the
issuance
of this promissory note and the related transfer of property and
equipment to SipStorm, Inc.

Note 9. Accounts Payable and Accrued Liabilities, page 66

3. We refer to the last paragraph on page 43 where you state, "we
accrue the amount of the charges we believe represent valid
charges
against us".  Explain to us in your response letter what you mean
by
"valid charges".  Does your determination of "valid charges" have
a
history of correlating with the amount of the charges that you end
up
paying?  Further we note your disclosure in Note 17 on page 71
that
states "we have accrued access charges we believe are probable of
payment."  Tell us whether you have accrued the $19.6 million of
disputed amounts at December 31, 2004.

4. Further, tell us in your response letter whether you have
accrued
for the $2.3 million back-billing of dispatch charges by Verizon,
as
discussed on page 44.  If not, explain to us in detail why you
believe an accrual was not necessary.

Note 13.  Mandatorily Redeemable Convertible Preferred Stock, page
68

5. Based on your disclosure, it appears that these transactions
constitute an induced conversion as defined by EITF Topic D-42 and
SFAS 84.  Please tell us in your response letter how you
considered
this guidance in accounting for the conversion of the Series D,
Series E, and Series G convertible preferred stock into shares of
your common stock.  Further, explain to us in detail how you
computed
the deemed dividend related to beneficial conversion feature of
$57.6
million and the mandatorily redeemable convertible preferred stock
dividends and accretion of $15.3 million for the year ended
December
31, 2004.  You may wish to provide us with journal entries to
facilitate our understanding of these transactions.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 Adam Washecka, Staff Accountant, at (202) 551-3375
or
Ivette Leon, Assistant Chief Accountant, at (202) 551-3351 if you
have questions regarding comments on the financial statements and
related matters.  Please contact me at (202) 551-3810 with any
other
questions.

								Sincerely,

								Larry Spirgel
								Assistant Director

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Mr. Horace J. Davis, III
Trinsic, Inc.
June 7, 2005
Page 4

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