SecProbe.io

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Mail Stop 3561

      August 2, 2005

Robert P. Farrell
Chief Executive Officer
Sagamore Holdings, Inc.
33 Wood Avenue South, Suite 600
Iselin, New Jersey  08830

	RE:  	Sagamore Holdings, Inc.
      Amendment No. 3 to Form SB-2
      Filed July 28, 2005
      File No. 333-122822

Dear Mr. Farrell:

      We have reviewed your amended Form SB-2 and response letter
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 information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.  Feel free to call us at the telephone
numbers
listed at the end of this letter.

General
1. We note your disclosure on page one that you recently entered
into
a forbearance agreement with Comerica Bank to extend the maturity
date of your revolver under the credit facility from July 1, 2005
to
August 1, 2005.  Please revise your disclosure, in the summary,
risk
factors and management`s discussion and analysis, to indicate
whether
you have further extended the maturity date, and, if you have not,
what your financial obligations are to Comerica Bank, Jaco and any
other lenders, in light of the outstanding balance under the
facility, the facility`s maturity date and your default that
apparently has not been waived.

In addition, if you have not further extended the maturity date or
replaced the facility, then include a risk factor that discusses
the
investment risk to holders of your common stock in the event that
you
liquidate your business; we note on page one you mention
liquidation
of your business as a possibility.

Management`s Discussion and Analysis, page 22

Overview, page 22
2. If your credit facility has matured, please accordingly revise
your disclosure of how you intend to meet your financial
obligations
over the next twelve months.
3. We note your response to our prior comment one, but, given that
you still indicate reliance on "cash flows from operating
activities
that [management] expects" to meet your financial obligations
through
April 2006, please describe the level of cash flows from operating
activities that management expects and the basis for such
expectation.  For example, if management expects that increased
cash
flows over the next year are necessary (as compared to the last
completed fiscal year) to meet its financial obligations, describe
the magnitude of the increase necessary and why management
believes
it is possible for the company to attain such cash flow levels.

Results of Operations, page 24

4. We note your response to our prior comment two.  Disclose, in
your
discussion of results of operations within management`s discussion
and analysis and within the notes to the financial statements of
Nexus, the amount and timing of and reasons for each of the
inventory
obsolescence charges.  In addition, confirm for us that these
charges
are included within "cost of sales" in your statement of
operations.

Where You Can Find More Information, page 45
5. Please revise to include the current address of our public
reference room in Washington, D.C. at 100 F. Street, N.E.

*	*	*	*

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your response to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
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 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.

      We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	You may contact Kenya Wright, Staff Accountant, at (202) 551-
3373, or Robert Littlepage, Accountant Branch Chief, at (202) 551-
3361, if you have any questions regarding comments on the
financial
statements and related matters.  Please contact Cheryl Grant,
Staff
Attorney, at (202) 551-3359, or me, at (202) 551-3810, with any
questions.

								Sincerely,

								Larry Spirgel
								Assistant Director

cc:	via facsimile (305-358-7095)
      Clayton Parker, Esq.
	Kirkpatrick & Lockhart Nicholson Graham LLP

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Mr. Farrell
Sagamore Holdings, Inc.
August 2, 2005
Page 3

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