Room 4561
						February 14, 2006



Mr. Stephen E. Pomeroy
Chief Executive Officer
Pomeroy IT Solutions, Inc.
1020 Petersburg Road
Hebron, KY 41048

Re:	Pomeroy IT Solutions, Inc.
	Form 10-K for Fiscal Year Ended January 5, 2005
	Filed April 5, 2005
	File No. 000-20022


Dear Mr. Pomeroy:

      We have reviewed your response letter dated December 29,
2005
and have the following additional comment.  We may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
After reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the Fiscal Year Ended January 5, 2005

Note 2.  Summary of Significant Accounting Policies

Revenue Recognition, page F-9

1. We have read your response to prior comment numbers 1 through
4.
Absent any additional substantive information indicating
otherwise,
it appears that revenue should be recognized upon shipment for
your
logistical deployment arrangements.  This is based on the
following:

* Fixed delivery schedules do not appear to exist due to your
practice of granting waivers that allow shipment to extend beyond
the
agreed-upon date.  In addition, we question whether the default
six-
month delivery schedule is substantive;
* The risks of ownership do not appear to have fully passed to the
buyer as evidenced by the fact that you appear to retain an
insurable
risk coupled with the contradictory contract language regarding
risk
of loss.

Please revise your revenue recognition policy to recognize this
revenue upon delivery or provide us with a detailed response that
further explains why you believe your accounting is correct.  This
response should refer to the relevant accounting literature that
supports your position and should address, in detail, the matters
identified above.  We may have further comment.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses 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 any amendment and your responses to our comments.

	You may contact Christine Davis, Staff Accountant, at (202)
551-
3408, Mark Kronforst, Senior Staff Accountant at (202) 551-3451 or
me
at (202) 551-3489 if you have questions regarding these comments.

Sincerely,



      Brad Skinner
							Accounting Branch Chief
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Mr. Stephen E. Pomeroy
Pomeroy IT Solutions, Inc.
February 14, 2006
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