B.H.I.T. Inc.
7005 Stadium Drive, Suite 100
Brecksville, Ohio 44141
June 12, 2007
Via EDGAR and U.S. Mail
Cicely L. LaMothe
Branch Chief
Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 4561
Washington, D.C. 20549
Re: B.H.I.T. Inc.
Form 10-KSB for the Fiscal Year Ended December 31, 2006
Form 10-QSB for the Quarter Ended March 31, 2007
SEC File No: 0-09043
Dear Ms. LaMothe,
In your May 31, 2007 letter you made the following comment to B.H.I.T. Inc.'s most recent Forms 10-KSB and 10-QSB:
We noted that the identification of the certifying individual at the beginning of the certification required by Exchange Act Rule 13a-14(a) also includes the title of the certifying individual. Considering that the certifications must be signed in a personal capacity, please confirm to us that your officers signed such certifications in a personal capacity and that you will revise your certifications in future filings to exclude the title of the certifying individual from the opening sentence.
I confirm that Paul S. Dennis and I signed the certifications required by Exchange Act Rule 13a-14(a) for B.H.I.T.'s December 31, 2006 Form 10-KSB and March 31, 2007 Form 10-QSB in our personal capacity. In future filings we will revise the certifications to exclude the title of the certifying individual from the opening sentence.
Per your request, B.H.I.T. acknowledges that:
- B.H.I.T. is responsible for the adequacy and accuracy of the disclosure in the company's filings with the Commission;
- Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and
- B.H.I.T. 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.
We trust that the foregoing is responsive to your comments. If you have any questions regarding B.H.I.T.'s responses set forth in this letter, please do not hesitate to contact our attorney, Christopher J. Hubbert, at 216-736-7215.
Sincerely,
B.H.I.T. Inc.
/s/ Andrew H. Scott
Andrew H. Scott
Interim Chief Executive Officer
cc: Jorge L. Bonilla
Paul S. Dennis
Christopher J. Hubbert