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MAIL STOP 3561

      	December 21, 2005

Nancy K. Hedrick
President and CEO
Computer Software Innovations, Inc.
1661 East Main Street
Easley, South Carolina 29640

      Re:	Computer Software Innovations, Inc.
      Registration Statement on Form SB-2
   File No. 333-129842
		Filed Date November 21, 2005

Dear Ms. Hedrick:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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.

General
1. Our research indicates that The Emerging Stock Report initiated
coverage of the company around October 14, 2005.  With a view
toward
disclosure, please provide us with the following information.
Firstly, whether the company, its` employees, directors, or
selling
shareholder has had any contacts with The Emerging Stock Report,
including, but not limited to, providing information, or
compensation
for reports.  Secondly, please provide any information regarding
The
Emerging Stock Reports current or previous holdings of your
company.
Finally, please provide any releases authored by The Emerging
Stock
Report relating to your company.
2. We note that the company is obligated to issue additional
shares
of preferred stock pursuant to a liquidated damages clause for
each
day beyond November 30 that the company has not registered the
resale
of the Barron LP shares.  Where appropriate, please revise your
disclosures to include the issuance of these shares.
3.  We note that the company amendment its` Form 10QSB/A for the
periods ended March 31, 2005 and June 30, 2005.  Please ensure
that
all financial figures, including the presentation of gross margins
and related percentages, are appropriately updated in the next
version of your registration statement.

Summary, page 4
4. We note your discussion on page 5 that you plan to acquire
additional businesses in the near future and have had preliminary
discussions with acquisition candidates.  In the appropriate
sections, please discuss how the company plans to finance any
acquisition in the future and add any material risk factors
discussing potential risks associated with this course of action.

Summary Financial Data, page 7
5. Please revise your "Selected Balance Sheet Data" presented on
page
7 to include items relevant to your liquidity, including cash and
accounts receivable.
6. We note that your reconciliation of pro forma net income
contains
two line items related to stock options.  Please explain the
difference in these items and why they are disclosed separately.
Without limiting the generality of the foregoing, please explain
in
the appropriate sections the origins of these stock options,
particularly if any options were given to customers in exchange
for
business.

Risk Factors, page 11
7. Please avoid the generic conclusion you reach in some of your
risk
factor subheadings that the risk will affect revenues, be
unfavorable
to us, or that your business will suffer.  Instead, replace this
language with specific disclosure of how your business and
operations
would be affected.  For example, see risk factors 1, 5, 7, 13 and
25.
8. Risk Factor 20, on page 16, appears speculative in light of the
fact that you currently do not have any active acquisition
targets.
Please revise this disclosure or, alternatively, advise us why no
revision is necessary.
9. You disclose, on page 57, that you license your software
through
unwritten, implied, nonexclusive licenses.  Please include a risk
factor describing the potential risks associated with this; in
particular, we note that a discussion regarding your ability to
enforce license terms and restrict use may be appropriate.

The Selling Stockholder, page 26
10. Please revise footnote (2) to the table to specifically state
the
amount of common stock that assumes the conversion of the common
stock or the exercise of the warrants to the maximum permitted by
the
Certificate of Designation and the warrants.
11. Please advise us of the nature of the consulting services
provided by Robert Steel.
12. We note your disclosure on page 27 that suggests that Messrs.
Sobel and Steel are independent directors.  Please disclose
whether
you have determined that Messrs. Sobel and Steel are independent
directors.  Please also include a statement whether these
directors
are independent from Barron and identify any instances where
Barron
or its affiliates may directly or indirectly control these
directors
or where such directors may control Baron.

Plan of Distribution, page 28
13. On page 30 you disclose that you have "agreed to pay
liquidated
damages to the selling stockholder in the form of additional
shares
of preferred stock if the registration statement is not timely
filed
or made effective or if the prospectus is unavailable for periods
in
excess of those permitted."  Elsewhere in your registration
statement, including on page 27, you state that the maximum number
of
preferred shares that can be issued is 1,082,736.  Please clarify
whether the registration rights agreement itself caps the shares
issuable as liquidated damages.  If not, please advise us of the
source for the 1,082,736 figure.
14. In your discussion of the registration rights agreement both
here
and elsewhere, please include disclosure relating to your payment
of
$50,000 to Barron as consideration for modifying the registration
rights agreement.  Alternatively, please advise why no disclosure
is
required.
15. We note the disclosure on page 30 regarding indemnification.
Please include the disclosure provided by Item 512(e) of
Regulation
S-B.

Market for Stock, page 31
16. We note your disclosure that, as of November 10, 2005, there
were
2,631,786 shares of your common stock outstanding.  Please clarify
whether this figure includes shares owned by officers/directors
subject to resale restrictions, or whether the figure represents
freely trading securities.  If the former, please include a
statement
disclosing the number of freely traded securities.  Alternatively,
please advise us why no revision is necessary.

Description of Business, page 31
17. The last sentence of the first paragraph on page 34, beginning
"[r]evenues from hardware sales ..." is unclear.  In particular,
the
clause "traditionally low margin products" appears circular if the
clause is being used to explain why hardware sales are at lower
margins.  Please revise, or advise us why no revision is
necessary.
18. On page 35 you disclose that Ms. Hedrick and Ms. Hawkins had
worked for Data Management, Inc. and developed an accounting
system
designed for local governments.  Please clarify whether this
development was concurrent with their work for Data Management,
Inc.,
or occurred afterwards.  If concurrent, please address any
Intellectual Property or employment issues in your response to us.
19. On page 37 you disclose that Messrs. Butta and Phillips were
introduced to the company as potential directors because of their
experience in intellectual property-based businesses.  Please
include
this experience, and its relevance, in their related biographies.
20. On page 38 you disclose that you received 5,042,250 from the
"[p]roceeds from sale of warrants in merger."  Please revise, or
advise us why no revision is necessary, to reflect that these
proceeds also include the sale of preferred stock.
21. In the fifth paragraph on page 42 you state that "[t]o avoid
doubt following conferences with the SEC, the parties agreed ..."
Please modify this language to avoid reference to the SEC as it
gives
the appearance that the SEC was a "party" to the discussion and/or
approved the result.
22. In the second bullet point on page 45 you disclose that the
preferred stock purchase agreement provided for liquidated damages
in
the event that you did not hire a chief financial officer within
the
specified time-frame.  If applicable, please revise your
disclosure
to address any damages payable in the future in the event that you
fail to have a chief financial officer due to resignation etc.
23. In your discussion of the pre-merger dividend on page 47 you
state that the dividend "transaction would not have occurred if
the
merger were not anticipated."  Please clarify what you mean by
this
statement.  In particular, if the dividend would not have been
possible but for Barron`s capital infusion then why isn`t this
transaction more properly described as a purchase from an
affiliate?

24. On page 47 you disclose that the original CSI-South Carolina
shareholders receive 2.5 million shares of the surviving company`s
common stock with an estimated value of $.6986 per share.  This
estimated value appears to be based on the price per share paid by
Barron for their preferred stock.  However, following the merger a
market existed for the shares CSI-South Carolina`s shareholders
received.  Please explain reasoning behind selecting the $.6986
per
share value.
25. On page 49 you refer to SQL and state that it refers to
"standard
query language."  Please verify that this is not supposed to be
"structured query language."
26. We reissue our prior comment 39 in its entirety.  In
particular,
we are looking for greater discussion on the nature of the
relationship the company has with these vendors and the material
terms of any agreements with these vendors.
27. On page 52 you state that "a strong referral base has been key
to
our success."  Please substantiate your strong referral base, or
alternatively, remove the reference.
28. In the first paragraph on page 54 under the heading "Expansion
of
Offerings," you disclose that you may expand into new areas such
as
metropolitan wireless networks, etc.  If management currently has
plans to expand into these areas, please discuss them more fully.
If
management does not have any plans to offer these services in the
near future, please provide a reasonable basis for the statement
or
remove.

Intellectual Property, page 57
29. Please expand your discussion of your licensing terms.
Without
limiting the generality of the foregoing, your discussion should
include items such as the duration of the license, the ability to
copy and/or share the license, and any restrictions on reverse
engineering.  Please also discuss how the company enforces its
licenses in the absence of a written license agreement.  In
addition,
you should include a discussion of any contracts the company uses
in
lieu of a license agreement.
30. Please include the percentage of revenues generated from the
Federal E-Rate Program in 2003 in your discussion on page 58.

Legal Proceedings, page 59
31. We note that you discuss an agreement between CSI-South
Carolina
and The Geneva Companies, Inc., on page 59.  Please advise us of
the
nature of the initial agreement and confirm whether the agreement
has
been filed.

Management`s Discussion and Analysis, page 61
32. Much of your discussion in this section, particularly the
overview subsection, repeats your prior discussion in the
"Description of Business" section.  Please revise to eliminate any
duplicative disclosure.  Please revise your overview subsection
accordingly and focus on providing insight into the company`s
challenges and risks of which management is aware and discuss any
actions being taken to address the same.
33. On page 67, in your discussion of your acquisition of the
Standards Based Lesson Planning software you state that "[t]he
software product ... and all related rights purchased did not
constitute a material addition to our business."  If this
discussion
is not material, please revise this discussion to indicate the
relevance.  In a related matter, we note that you have a
commission
plan and consulting agreement with Eric Levitt related to this
software product.  Please include disclosure, if material, of the
commission rates and other amounts payable under the agreement.
If
you have not done so, please file a copy of this agreement.
34. Please expand your revenue discussion on page 72 to address
why
new software sales declined as a result of an increase in support
revenue.  In addition, please discuss the affect that this will
have
on future revenue growth.
35. In your revenue discussion on page 72 and 73 you mention the
addition of new sales persons in the last quarter as well as new
sales persons in new geographic areas.  Please discuss when
management believes that these new employees will have an impact
on
sales and sales growth.
36. In your tabular presentation on page 72 you present a positive
balance associated with salaries, wages and benefit related
operating
expenses.  Please confirm whether this means that this category of
expenses declined by $592,647 in the nine month period ended
September 30, 2005.  In addition, please discuss the reason for
this
variance.
37. In the third full paragraph on page 73, you state that reverse
acquisition costs included $275,000 in commissions paid to a
third-
party broker, Liberty Capital LLC.  Please describe Liberty
Capital`s
involvement in the reverse acquisition and describe the structure
of
its commission, e.g. whether it was a transactional fee.  Also
disclose whether Liberty Capital is a registered broker-dealer.
38. Please expand your discussion of interest and other income and
expenses on page 75 to discuss the company`s outstanding debt
balances, and related interest rates.  In addition, please explain
the nature of the unrealized loss on warrants.

39. In the tabular presentation on page 77 you present a $48,000
gain
from "Other."  Please explain the nature of this gain.  In
addition,
please explain the items included in the $172,198 "Other
miscellaneous" balance on page 78.
40. Given the deterioration in the company`s cash position
relative
to year-end, please address whether the company believes it will
be
able to meet its` debt obligations as they come due.  In addition,
please discuss the terms of the bank revolving credit agreement,
including any covenant violations and their implications to the
business.
41. Please separately address recurring and non-recurring items
causing the decline in cash flows from operations for the nine
month
period ended September 30, 2005 versus 2004.
42. Please include a discussion of cash generated/used through
investing activities for the nine months ended September 30, 2005
and
2004.
43. Please indicate, in your discussion of "Credit Arrangements"
on
page 80 whether your loan is secured by an interest in your
accounts
receivable, or merely limited by your accounts receivable.  In
addition, please describe the nature of the acceleration
provisions
contained in your agreement, and their potential effect on the
company.
44. On page 80 we note that the company incurred approximately
$700,000 in legal and accounting fees related to the merger which
they have presented in "Cash from Operating Activities."  Please
advise us why the legal expenses related to the financing are not
presented in the "Cash from Financing Activities" section.
45. We note your disclosure on page 81 that you have increased
your
draw on your credit line to $2.6 million from $1.7 million between
November 10, 2005 and September 30, 2005.  Please explain the
reason