Mail Stop 3561

      May 24, 2006

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

      Re:	Sputnik, Inc.
   Amendment No. 10 to Registration Statement on
   Form SB-2
      Filed May 10, 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.

Use of Proceeds, page 10

1. Please update to include any additional expenses to be paid,
directly or indirectly, to GoPublicToday.com from the use of
proceeds, if any.

Security Ownership of Certain Beneficial Owners and Management,
page
16

2. Please update this section.


Management`s Discussion and Analysis of Financial Condition and
Results of Operation,

Results of Operations For the Three Months Ended March 31, 2006
Compared to the Three Months Ended March 31, 2005, page 24

3. Please discuss the reasons for the increase in gross profit
percentage from 55% to 65% on a substantial decrease in revenues.

4. Define "recognized ratably."

Liquidity and Capital Resources, page 25

5. We note deletion of disclosure regarding the company`s issuance
of
common stock during the last fiscal year.  It would appear that
the
issuance of common stock as a form of financing or liquidity would
be
important to investors.  Please revise or advise.  In addition, we
note the deletion of the description of the amount of the legal
debt
owed to DLA Piper Rudnick Gray Cary, LLC and the statement that
the
debt is described elsewhere. We were unable to find the
description
of this debt elsewhere.  Please include the amount owed and revise
accordingly.

Certain Relationships and Related Transactions

6. Indicate the nature of the relationship between the registrant
and
GoPublicToday.com and disclose the beneficial owner(s) of
GoPublicToday.com.

7. GoPublicToday.com is clearly a promoter of the company and
should
be indicated as such.

8. Clarify the owners of Public Company Management Services, Inc.

9. Update the December 31, 2005 dates mentioned throughout this
section to the latest date practicable prior to effectiveness of
the
registration statement.

Other

10. The reference to the report date of January 25, 2006 in the
consent of the independent registered public accounting firm is
inconsistent with the audit report date of May 9, 2006 included in
the registration statement.  Please revise.





* * * * *

      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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      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.
May 24, 2006
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