Mail Stop 3561

      April 12, 2006

Mr. David LaDuke, President
Sputnik, Inc.
650 Townsend Street, Suite 320
San Francisco, CA 94103

      Re:	Sputnik, Inc.
   Amendment No. 7 to Registration Statement on
   Form SB-2
      Filed March 29, 2006
		File No. 333-126158

Dear Mr. LaDuke:

      We have reviewed your amended filing and have the following
comments.  Where indicated, we think you should revise your
document
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Back Cover Page of Prospectus

1. Please remove from the back cover page of the prospectus any
information not required by Item 502 of Regulation S-B.

Security Ownership of Certain Beneficial Owners and Management,
page
18

2. In the table, please include the home address of Kathy Giori
for
she does not appear to be an officer or director of the company.

Notes to Financial Statements

Note 1 - Summary of Significant Accounting Policies

Allowance for Doubtful Accounts, page 40

3. We read your response to our previous comment 11 and your
reference to the response to comment 9; however we do not see
where
you have addressed our comment.  Your current disclosure indicates
your expense for money back guarantees is included in bad debt
expense.  Although we understand from your previous response that
your returns (i.e. money back guarantees) were insignificant, your
policy (to record as bad debt expense) is not GAAP.  Accordingly,
you
should revise to disclose a policy that is GAAP (for example,
estimates for returns are recorded as a reduction in revenue
pursuant
to paragraph 7 of SFAS 48).  If you elect to follow a policy that
is
not GAAP, revise to explicitly state as such, and provide a
discussion as to why you believe your accounting treatment is more
appropriate that GAAP.

Other

4. The reference to the report date of April 15, 2005 in the
consent
of the independent registered public accounting firm is
inconsistent
with the audit report date of January 25, 2006 included in the
registration statement.  Please revise.

Item 26. Recent Sales of Unregistered Securities

5. We note your response to our prior comment 13.  Please note
that
under the federal securities laws, the issuance of 65,000 shares
of
the company`s common stock to consultants on December 16, 2005 in
consideration for services would constitute the sale of
securities.
Please explain the exemption you relied upon in conducting these
private placements given that an issuer generally is not allowed
to
transact a private placement concurrent with a public offering,
with
very limited exceptions, See Black Box Inc. (June 26, 1990).
Generally, the filing of a company`s registration statement
constitutes a general solicitation of the company`s securities.
We
note the subsequent securities transactions by the company after
the
filing of the registration statement.  Provide us with legal and
factual basis underlying the exemption from registration claimed
for
the issuance of these securities.  We may have further comment.

* * * * *

      As appropriate, please amend your registration statement in
response to these comments.  Provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your response to our comments and
provides
any requested supplemental information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Angela Halac at (202) 551-3398 or Hugh West
at
(202) 551-3872 if you have questions regarding comments on the
financial statements and related matters.  Please contact Thomas
Kluck at (202) 551-3233 with any other questions.

								Sincerely,



								John Reynolds
      Assistant Director

cc:	Michael Williams
	Fax (813) 832-5284

David LaDuke
Sputnik, Inc.
April 12, 2006
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