CORRESP

[Correspondence to the SEC]

BLUEGATE CORPORATION

701 North Post Oak, Road, Suite 600

Houston, Texas 77024

voice:  (713) 686-1100

fax:  713-682-7402

March 1, 2010

H. Christopher Owings

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3561

Washington, D. C. 20549-3561

Re: Bluegate Corporation

      Preliminary Information Statement on Schedule 14C filed November 10, 2009

      File No. 000-22711

Dear Mr. Owings:

This letter is in response to your comments contained in the letter to our Chief Executive Officer, Stephen J. Sperco, dated February 19, 2010.

Enclosed please find our acknowledgement letter and memorandum of responses.

Respectfully yours,

/s/ Charles E. Leibold

Charles E. Leibold

Chief Financial Officer

CORRESP

[Correspondence to the SEC]

BLUEGATE CORPORATION

701 North Post Oak, Road, Suite 600

Houston, Texas 77024

voice:  (713) 686-1100

fax:  713-682-7402

March 1, 2010

H. Christopher Owings

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3561

Washington, D. C. 20549-3561

Re: Bluegate Corporation

      Preliminary Information Statement on Schedule 14C filed November 10, 2009

      File No. 000-22711

Dear Mr. Owings:

Company Acknowledgements

The Company submits the following acknowledgements:

Bluegate Corporation is responsible for the adequacy and accuracy of the disclosure in the filing.

Bluegate Corporation acknowledges that staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing.

Bluegate Corporation 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.

Respectfully yours,

/s/ Charles E. Leibold

Charles E. Leibold

Chief Financial Officer

CORRESP

[Correspondence to the SEC]

BLUEGATE CORPORATION

Memorandum of Responses to SEC Comment letter dated February 19, 2010

SEC comment 1 – General

1. Please file a revised preliminary information statement that incorporates the changes requested in our letter dated December 8, 2009, as well as the changes requested in this letter. Also update all information as of the most recent practicable date. For example, update the executive compensation information for the fiscal year ended 2009.

Bluegate response to comment 1 -

The preliminary information statement has been amended to incorporate the changes requested in your letters dated December 8, 2009 and February 19, 2010 and is filed as Amendment 1.

SEC comment 2 – General

2. We note your response to comment two of our letter dated December 8, 2009. Please revise the disclosure throughout your information statement to (i) clarify that the actions approved by the shareholder consent have been taken and indicate when they were taken, (ii) clarify that the fact that such actions have been taken may be inconsistent with Rule 14c-2(b) under the Exchange Act, and (iii) describe the reasons that you determined to take such actions prior to the time period specified in Rule 14c-2(b) under the Exchange Act.

Bluegate response to comment 2 –

The following disclosure has been included throughout the information statement. “It was intended that the results of the resolutions approved in the shareholder consent be held in escrow pending effectiveness of the filing; however in order to complete the transactions and avoid filing for bankruptcy, it was agreed that funds would have to be paid by November 11, 2009 and the actions approved by the shareholder consent were taken effective November 7, 2009. The actions taken may be inconsistent with Rule 14c-2(b) under the Exchange Act; however, we believed that by taking those actions and filing Form 8-K disclosing the disposition of certain assets and business was more useful for the shareholders even though those actions were taken prior to the time period specified in Rule 14c-2(b) under the Exchange Act.”

SEC comment 3 – General

3. We note your response to comment four of our letter dated December 8, 2009. Please include the fairness opinion, as revised by Convergent Capital Appraisers, in the information statement. Also include the material agreements relating to the transaction.

[Correspondence to the SEC]

BLUEGATE CORPORATION

Bluegate response to comment 3 –

We have included the fairness opinion, as revised by Convergent Capital Appraisers and the material agreements relating to the transaction in the information statement.

SEC comment 4 – General

4. It appears from your response to comment five of our letter dated December 8, 2009 that the assets disposed of in the transaction comprise “all or any substantial part of assets” and, therefore, you should revise your filing to include all of the disclosure required by Item 14 of Schedule 14A. See Item 14(b) (1), (3), and (5) through (11) of Schedule 14A. Please note that we may have further comments after reviewing this additional disclosure.

Bluegate response to comment 4 –

We have revised the filing to include all of the disclosure required by Item 14 of Schedule 14A, specifically Item 14(b) (1), (3), and (5) through (11) of Schedule 14A.