SendTec, Inc. 877 Executive Center Drive West Suite 300 St. Petersburg, Florida 33702 October 25, 2006 United States Securities and Exchange Commission Division of Corporation Finance Mail Stop 3720 100 F Street NE Washington, DC 20549 Attn: Larry Spirgel RE: SendTec, Inc. Amendment No. 1 to the Preliminary Proxy Statement on Schedule 14A Filed October 17, 2006 File No. 0-51702 Ladies and Gentlemen: In connection with filing the Definitive Proxy Statement on Schedule 14A of SendTec, Inc. (the "Company"), the Company hereby acknowledges that: o the Company is responsible for the adequacy and accuracy of the disclosure in the filing; o staff comments or changes to disclosure in response to staff comments do not foreclose the Securities and Exchange Commission (the "SEC") from taking any action with respect to the filing; and o the Company may not assert staff comments as a defense in any proceeding initiated by the SEC or any person under federal securities laws of the United States. Very truly yours, /s/ Paul Soltoff Paul Soltoff Chief Executive Officer
