GERSTEN, SAVAGE, KAPLOWITZ, WOLF & MARCUS, LLP
                              600 LEXINGTON AVENUE
                            NEW YORK, NEW YORK 10022



                                                               February 11, 2005




United States
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention:  Cheryl Grant, Esq.

         RE:      FUSION TELECOMMUNICATIONS INTERNATIONAL, INC.
                  FILE NO, 333-120412

Dear Ms. Grant:

         Please see our responses to your written comments of February 11, 2005.

         Response #1:

                  As the Company stated, they track off-net revenues by customer
         and product.  The Company  tracks off-net costs of revenues by provider
         (vendor).  This tracking  analysis is consistent with the disclosure in
         the book.

         Response #2:

                  Please note that the Company  believes  that it was  operating
         within the statute and notes the fact that it  represented a very small
         amount of revenues. More importantly, the Company does not believe that
         the fact that  Efonica  had  dealings  with Libya  during the time that
         Libya was both  identified  as a state sponsor of terrorism and subject
         to  OFAC-administered  economic sanctions raises any risk that it would
         have a  potential  impact on Fusion's  reputation  and share value that
         would  cause  Efonica's  relationship  with the Libyan  reseller  to be
         material  to  Fusion  or  pose a  material  risk to  Fusion's  security
         holders,  especially  considering  the  current  status  of the  United
         State's relationship with Libya.


                                            Sincerely,


                                            \s\ Arthur S. Marcus, Esq.
                                            --------------------------
                                             Arthur S. Marcus, Esq.