SecProbe.io

October 6, 2010
 John Salerno Chief Executive Officer  iGambit, Inc. 1600 Calebs Path Extension, Suite 114 Hauppauge, New York  11788

Re:  iGambit, Inc.
Amendment No. 2 to Registrati on Statement on Form 10
Filed September 13, 2010  Amendment No. 1 to Form 10-K Filed September 13, 2010  Form 10-Q for Fiscal Period Ended June 30, 2010 Filed August 16, 2010
File No. 000-53862

Dear Mr. Salerno:
We have reviewed the amendments to your registration statement and periodic filings and
have the following comments. In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
 Please respond to this letter within te n business days by amending your registration
statement and periodic reports, and by providing the requested information. If you do not believe
our comments apply to your facts and circum stances or do not believe an amendment is
appropriate, please tell us  why in your response.
 After reviewing any amendment to your regi stration statement and periodic reports, and
the information you provide in response to thes e comments, we may have  additional comments.

General

1. Please apply all comments relating to the Form  10 to your Form 10-K for the fiscal year
ended December 31, 2009, Form 10-Q for th e fiscal period ended March 31, 2010, and
Form 10-Q for the fiscal period ended June 30, 2010, as applicable.

John Salerno iGambit, Inc. October 6, 2010 Page 2

Amendment No. 2 to Registration Statement on Form 10

 Item 2. Financial Information, page 6

 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page 7

 Liquidity and Capital Resources, page 8

 Cash Flow Activity, page 8

2. We note the changes made in response to comment 11 in our letter dated July 1, 2010.
Please provide a discussion and analysis of your cash flows from operating, investing and
financing activities for all the periods covered by the financia l statements required to be
included in the Registration Statement incl uding the cash flow activities for the years
ended December 31, 2009 and December 31, 2008.
 3. Please tell us how you compute Gotham net losses of $124,954 for 2009 and $152,549
for the six months ended June 30, 2010.  Pleas e provide reconciliations of these amounts
to your losses from continuing operations to  help our understanding.  In addition, explain
why Gotham net loss as presented is not  a non-GAAP measure as defined at Item
10(e)(2) of Regulation S-K.
 Item 10. Recent Sales of Unregistered Securities, page 12

4. We note your revised disclosure in respons e to comment 16 in our letter dated July 1,
2010.  Please further revise your disclosure to  state the aggregate offering price of all
common stock, options and warrants that were  sold for cash, the nature and aggregate
amount of consideration received for common stock, options and warrants that were sold
otherwise than for cash, and the value of any common stoc k issued upon exercise of
warrants or options.  Refer to It em 701(c) of Regulation S-K.  In addition, please revise
this section to state briefly the facts relied upon to make the exemptions available. Refer
to Item 701(d) of Regulation S-K.
 Item 15. Financial Statements and Exhibits, page 13

5. It appears that the financia l statements included in your  Registration Statement do not
comply with the requirements in Rule 8-02 of Regulation S-X.  Please amend to include the appropriate annual financial statements.
 6. We reviewed your response to comment 17 in our letter dated July 1, 2010.  As
previously requested, please provide us w ith the significance tests performed which
support the Jekyll Island Ventures, Inc. financia l statement periods that are required to be
presented.  Refer to Rule 8-04 of Regulation S-X.

John Salerno iGambit, Inc. October 6, 2010 Page 3

Report of Independent Registered  Public Accountant, page F-1

 7. Please include a manual or printed signature of the auditor’s firm in the audit report
presented in this Registration Statement and Amendment No. 1 to Form 10-K filed
September 13, 2010.  Refer to Rule 2-02(a) of Regulation S-X.

Consolidated Statements of Income, page F-3

 8. Please revise your filing to disclose  the appropriate amount of unrecognized
compensation cost related to each period pr esented.  In this regard, the amount of
unrecognized compensation cost appears unc hanged between Amendment No. 1 and
Amendment No. 2 to Form 10.

Exhibits

9. We note your response to comment 32 in our letter dated July 1, 2010.  Please include in
your filing, for example as footnotes to Exhi bits 2.1 and 2.2 in the exhibit index, your
agreement to furnish us with any omitted sche dule or exhibit upon request.  Refer to Item
601(b)(2) of Regulation S-K.
Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2009

 Financial Statement, page F-1

 Consolidated Statements of Cash Flows fo r the Years Ended December 31, 2009 and 2008, page
F-5

10. We reviewed your response to comment 10 in our letter dated July 1, 2010.  Please
explain why net cash provided by disconti nued investing activiti es totaling $938,481 for
the year ended December 31, 2009 and 434,811 for the year ended December 31, 2008
presented in the statements of cash flows do not agree to your disc losure in the first
paragraph on page 8 stating that cash pa yments received from DDC totaled $1,383,514 in
the year ended December 31, 2009 and $726,596 in the twelve months ended December 31, 2008.   In light of these amounts disclosed in the first paragraph on page 8 and the
comment below, please re-evaluate the am ounts presented as net cash provided by
discontinued operating, investi ng and financing activities.  Please also re-evaluate the
amounts presented as net cash (used) provi ded by discontinued ope rating, investing and
financing activities in the six months e nded June 30, 2010 and June 30, 2009.

11. Please explain why your classificatio n of the $141,538 repayment of prepaid
contingencies and the $350,000 payment for unpa id compensation as financing activities
rather than non-cash or operating activities  complies with the guidance in ASC 230.  To
the extent you change your presentation of  the repayment of prepaid contingencies,

John Salerno iGambit, Inc. October 6, 2010 Page 4

please make similar changes to your presentati on in the statement of cash flows for the
six months ended June 30, 2009.

Note 1 – Organization and Basis of Presentation, page F-6

 Business Acquisition, page F-6

12. We reviewed your response to comment 22 in  our letter dated July  1, 2010 and have the
following additional concerns:
• According to your disclosure, in conn ection with the business combination you
issued shares and options with a to tal fair value of $185,000.  However, you
recorded total net assets of $258,974 consisting of goodwill, cash, accounts
receivable and fixed assets.  Please expl ain how this inconsistency complies with
ASC 805.;
• In addition, please explain how you identif ied and recognized the assets acquired
in the business combination includin g your consideration of recognizing
intangible assets such as favorable or unf avorable sales contract terms.  Refer to
ASC 805-20.; and
• Tell us how the assets id entified and recognized differ from the book value of
Jekyll’s assets prior to the acquisition.
• Finally, referring to the valu ation of the common shares  and options issued, please
explain your consideration of events subsequent to October 24, 2005 when
valuing the common shares and options issued in the business combination.
Please also reconcile your statement in th e response that you only had net income
from discontinued operations contingency payments as of October 25, 2005 to the disclosure in Note 2 that Digi-D ata was sold on February 28, 2006.
 13. We reviewed your response to comment 26 in ou r letter dated July 1, 2010.  Please tell us
what portion of the fiscal 2009 $65,000 bad debt charge relates to the receivable balance
purchased from Digi-Data.  If not already expl ained in response to the comment directly
above, please also explain your considerati on of the uncertainty of future cash flows
when determining the fair value of the Digi -Data receivable bala nce recorded in the
business combination.  Refer to ASC 805-20.

Note 5 – Stock Based Compensation, page F-10

14. We reviewed your response to comment 27 in our letter dated July 1, 2010.  With respect
to the valuation of your common shares unde rlying your option and warrant issuances,
please explain your considerati on of events subsequent to October 24, 2005 for use in the
valuation models.  For example, explain your consideration of the expiration of a
significant portion of the five year conti ngency payment term with Digi-Data and the

John Salerno iGambit, Inc. October 6, 2010 Page 5

issuance of any securities.  Please also rec oncile your statement in the response that you
only had net income from discontinued operatio ns contingency payments as of October
25, 2005 to the disclosure in Note 2 that Digi-Data was sold on February 28, 2006.

Note 7. Income Taxes, page F-11

 15. We reviewed your response to comment 30 in  our letter dated July 1, 2010.    Please
explain why an effective tax rate of 47% is  appropriate for discon tinued operations.
 16. We reviewed your response to comment 31 in our letter dated July 1, 2010.  Please
disclose a reconciliation usi ng percentages or dollar amount s of the reported amount of
income tax expense attributable to continui ng operations to the amount of income tax
expense that would result from applying domes tic federal statutory tax rates to pretax
income from continuing operations.   Refe r to FASB ASC 740-10-50-12.  Your current
disclosure states only the federal and stat e statutory rates and pr ovides no reconciliation
to the reported amount of income tax expens e attributable to c ontinuing operations.

Form 10-Q for Fiscal Period Ended June 30, 2010

17. We note your statement that there were “ no changes in our internal controls over
financial reporting during the first fiscal quarter of 2010. . . .”  Please supplementally
confirm that this statement is intended to refer to the second fiscal quarter of 2010.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require. Si nce the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
You may contact Adam Phippen, Staff Accountant, at (202) 551-3336 or Jason
Niethamer, Assistant Chief Accountant, at (202) 551-3855 if you have questions regarding
comments on the financial statements and related matters.  Please contact Lilyanna L. Peyser,
Attorney Advisor, at (202) 551-3222 or me  at (202) 551-3725 with any questions.

Sincerely,    H. Christopher Owings  Assistant Director
 cc:  Joel D. Mayersohn, Esq.
Via Facsimile