POMEROY IT Solutions
[LOGO OMITTED]
1020 Petersburg Road
Hebron, KY 41048
Phone: 859.586.0600
October 25, 2006
Securities and Exchange Commission
Attention: Brad Skinner, Accounting Branch Chief
100 F. Street, N.E.
Washington, DC 20549
Re: Pomeroy IT Solutions, Inc.
File No. 000-20022
Dear Mr. Skinner:
Pomeroy IT Solutions, Inc., a Delaware corporation (the "Company" or "Pomeroy"),
hereby supplements its letter, dated September 15, 2006, with the additional
response set forth below to your follow-up Comment Letter, dated August 22, 2006
(the "Comment Letter"), pertaining to the Company's classification of cash
overdrafts on the Form 10-Q filed August 14, 2006.
Our response set forth below corresponds to the numbered comment in the Comment
Letter. For your convenience, we have included your original comment from the
Comment Letter followed by the Company's response.
FORM 10-Q FILED AUGUST 14, 2006
- -------------------------------
1. PLEASE EXPLAIN TO US YOUR BASIS FOR CLASSIFYING THE CASH
OVERDRAFT AS AN OPERATING CASH FLOW.
Revised Response:
------------------
In light of recent telephone conversations with the SEC staff, Pomeroy
acknowledges the SEC's position as expressed in "SEC Accounting Disclosure
Rules and Practices Official Text, Appendix A: "Form and content of
Financial Statements," that generally, cash overdrafts should be presented
as a financing activity. The Company agrees that all future filings will
classify these cash overdrafts as financing activities.
Thank you for your comments. If you have any questions, please contact our
counsel, Elizabeth A. Horwitz at (513) 852-6032, or me at (859) 586-0600, ext.
1416.
Sincerely,
/s/Kevin G. Gregory
---------------------
Kevin G. Gregory
Senior Vice President & Chief Financial Officer
cc: Elizabeth A. Horwitz, Esq., Wood & Lamping LLP
Sean Henaghan, BDO Seidman, LLP