SecProbe.io

December 20, 2010
 John Salerno Chief Executive Officer  iGambit, Inc. 1600 Calebs Path Extension, Suite 114 Hauppauge, New York  11788

Re:  iGambit, Inc.
Amendment No. 3 to Registrati on Statement on Form 10
Filed December 6, 2010  Form 10-K/A for Fiscal Year Ended December 31, 2009 Filed September 13, 2010 Form 10-Q/A for Fiscal Period Ended March 31, 2010 Filed September 13, 2010 Form 10-Q for Fiscal Period Ended June 30, 2010 Filed August 16, 2010 Form 10-Q for Fiscal Period Ended September 30, 2010 Filed November 22, 2010
File No. 000-53862

Dear Mr. Salerno:
We have reviewed the amendment to your regi stration statement and your periodic report
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 amendments to your regist ration statement and periodic reports, and
the information you provide in response to thes e comments, we may have  additional comments.

General

1. We note your response to comment one in our  letter dated October 6, 2010 and await the
filing of the relevant amendments.  Please also include your Form 10-Q for the fiscal
period ended September 30, 2010 in your revisi ons consistent with that comment.

John Salerno iGambit, Inc. December 20, 2010 Page 2

Amendment No. 3 to Registration Statement on Form 10

 Item 2. Financial Information, page 13

 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
14
 Liquidity and Capital Resources, page 16

2. We reviewed your response to comment th ree in our letter dated October 6, 2010.  As
previously requested, please tell us why Go tham net loss for the year ended December
31, 2009 and nine months ended Septembe r 30, 2010 as presented are not non-GAAP
measures as defined at Item 10(e)(2) of Regul ation S-K.  In addition, based on the tables
provided in response to comment three it appear s that discrete financial information is
available for Gotham and IGambit.  If not , please advise.  If so, please tell us the
operating segments you have identified in accordance with ASC 280-10-50-1 through 50-9 and explain your consideration of pr oviding the disclosures at ASC 280-10-50-20
through 50-42 in the notes to your financial statements.

Annual Financial Statements, page F-1

Report of Independent Registered  Public Accountant, page F-1

3. Your auditor should include an explanatory paragraph in his report referring to the
restatement described in Note 4 and date th e report appropriately.  Refer to Auditing
Standards Codification Sections AU 420.12 and 530.05.
 Consolidated Statements of Cash Flows, page F-5

4. We reviewed your response to comment te n in our letter date d October 6, 2010.  It
appears that net cash provided by discontinue d operations for the years ended December
31, 2009 and December 31, 2008 and for the nine months ended September 30, 2010 and September 30, 2009 presented in your statements of  cash flows still is not consistent with
the disclosure of cash received from DDC disc losed on page 9.  Further, the disclosure of
cash received from DDC disclosed in your di scussion of cash flow activity beginning on
page 16 appears inconsistent and/or incomp lete when comparing the discussion to the
disclosure of cash received from DDC disc losed on page 9 and the net cash provided by
discontinued operations for the years e nded December 31, 2009 and December 31, 2008
and for the nine months ended Septembe r 30, 2010 and September 30, 2009 presented in
your statements of cash flows.  Please re vise and/or reconcile for us the amounts
disclosed on page 9, in your discussion of  cash flow activity beginning on page 16 and
the net cash provided by disc ontinued operations for the years ended December 31, 2009
and December 31, 2008 and for the nine months ended September 30, 2010 and September 30, 2009 presented in your statements of cash flows.

John Salerno iGambit, Inc. December 20, 2010 Page 3

5. We reviewed your response to comment 11 in  our letter dated October 6, 2010.  Please
explain why your classification of the $141,538 repayment of prepaid contingencies as
net cash used in operating ac tivities rather than a non-cas h activity, considering the
disclosure in the second para graph on page F-9 that this amount was repaid with
contingency payments retained by DDC, or net cash used in financing activities complies with the guidance in ASC 230.
 6. We note the changes made to your statem ents of cash flows for the years ended
December 31, 2009 and December 31, 2008 and the nine months ended September 30, 2009.  Please tell us your consideration of labe ling the statements of cash flows for the
years ended December 31, 2008 and the nine months ended September 30, 2009 as restated.  Please also tell us your consider ation of providing the disclosures at ASC 250-
10-50-7 regarding corrections of errors.
 Notes to Financial Statements, page F-6

 Note 4. Restatement of Prior Period Conso lidated Financial Statements, page F-11

7. We reviewed your revision made in respons e to comment eight in our letter dated
October 6, 2010 noting that you revised to recognize $49,500 of compensation expense
from vested warrants in the three month period ended June 30, 2010.  Please tell the
amount of stock based compensation expense recognized from both warrants and options
in the three month periods ended Marc h 31, 2010, June 30, 2010 and September 30, 2010
and explain why the compensation expense re cognized complies with ASC 718.  In this
regard, please explain why this footnote doe s not refer to any stock based compensation
expense being recognized in the three months ended March 31, 2010 and why this
footnote and the statement of stockholders’ equity for the nine months ended September
30, 2010 on page F-20 does not refer to stock based compensation related to options.
 8. Please tell us whether you intend to reconsider  the adequacy of your previous disclosures
in your periodic reports rega rding the effectiven ess of your internal controls over
financial reporting and disclosu re controls and procedures in  light of the restatements.
Also tell us whether you inte nd to amend your periodic report s to revise your disclosure
and describe the effect of the restatemen t on the officers’ conclusions regarding the
effectiveness of your internal controls over financial reporting and disclosure controls
and procedures.  If your certify ing officers’ conclude that your internal controls over
financial reporting and disclosure controls  and procedures are effective despite the
restatement, please tell us the basis for the officers’ conclusions.

Note 1. Organization and Basi s of Presentation, page F-6

Business Acquisition, page F-6

9. We reviewed your response to comment 12 in our letter dated Oct ober 6, 2010 as well as
the revisions made in response to this comment.  As previ ously requested, please explain
how you identified and recogni zed the assets acquired in  the business combination

John Salerno iGambit, Inc. December 20, 2010 Page 4

including your consideration of recognizing intangible assets such as favorable or
unfavorable sales contract terms.  Refer to  ASC 805-20.  Please al so tell us how the
assets identified and recognized differ from the book value of Jekyll’s assets prior to the
acquisition.  In addition, see the comments  below regarding the accounts receivable
purchased and the valuation of the common shar es and options issued as consideration.

10. We reviewed your response to comment 13 in  our letter dated Oc tober 6, 2010 and note
your statement that the accounts receivable purchased were in good standing.  We also
note your independent public accountant’s disclosure on page F-38 that Jekyll should
have had a $46,000 accounts receivable reserve as of September 30, 2009.  Please reconcile this appare nt discrepancy.
 Note 6. Stock Based Compensation, page F-12

11. Reference is made to your response to comme nt 29 in our letter dated July 1, 2010 in
which you state that that the measurement da tes used for the warrants granted to the
securities broker firm and securities law firm comply with FA SB ASC 505-50-30-11 and
505-50-30-12.  Please tell us the measuremen t dates used for these warrants granted
through and including September 30, 2010 e xplaining why such measurement dates
comply with FASB ASC 505-50-30-11 and 505- 50-30-12.  Please also see the comment
below regarding the valuation of common shares  used in the valuation of warrants.

12. Please tell us if the weighted average grant- date fair value of the warrants and options
disclosed as $0.10 in the tables on page F-12 and F-27 represent the fair value of the
warrants and options, the common shares underlying the warrants and options, or both.  If
both, please confirm that the option pricing m odel used computed a grant-date fair value
of $0.10 using a $0.10 per common share fair va lue and the assumptions disclosed on
page F-13 and F-27.  If the amount disclosed represents only the fair value of the
common shares underlying the warrants and options, please disclose the weighted-
average grant date fair value of the warra nts and options.  Refer to ASC 718-10-50-2d.1.
 13. We reviewed your responses to comments 12 and 14 in our letter dated October 6, 2010,
your response to comment 29 in our lett er dated July 1, 2010 and your disclosures
throughout the Registration Statement.  It appears that you have used a $0.10 common
share fair value when: 1) valuing the comm on shares and the common shares underlying
options issued in the DDC acquisition, 2) va luing the common shares  underlying options
and warrants granted in the years en ded December 31, 2008 and December 31, 2009 and
the nine months ended September 30, 2010, and 3) measuring the common shares underlying the warrants granted to  the securities broker firm and securities law firm in
compliance with FASB ASC 505-50-30-11 and 505-50-30-12 as of the end of each
reporting period.  If not, please a dvise.  If so, please explai n why the fair value of your
common shares has not changed from December 31, 2008 through September 30, 2009 considering the expiration of a significant por tion of the five year contingency payment
term with DDC, the issuance of any securi ties and the purchase and of Jekyll.

John Salerno iGambit, Inc. December 20, 2010 Page 5

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