April 14, 2009

Securities and Exchange Commission
100 F Street N.E.
Washington, D.C.  20549

Attn:    Donna Levy, Esq.

Re:      Direct Insite Corp.
         Amendment No. 1 to Registration Statement on Form S-1
         filed February 19, 2009
         File No. 333-153792

Ladies and Gentlemen:

     On behalf of Direct  Insite Corp.  (the  "Company"),  the following are our
responses, including supplemental information, to the comments of the Securities
and Exchange Commission ("SEC") set forth in its letter dated March 5, 2009 with
respect to the  above-referenced  document  filed by the  Company.  Supplemental
information  provided  to you in this  letter is based upon  information  and/or
documentation provided by the Company. The numbers of our responses parallel the
numbers in your  March 5, 2009  comment  letter.  We are  providing  a hard copy
blacklined version of the Registration Statement to facilitate your review

General
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     1. Please be advised  supplementally that we have previously replied to the
staff comments on the confidential treatment request.


     2. Please be advised  supplementally  that we have revised the Registration
Statement  to include  audited  financial  statements  for the fiscal year ended
December 31, 2008.


Securities and Exchange Commission
April 14, 2009
Page -2-


Management's  Discussion  and  Analysis of  Financial  Condition  and Results of
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Operations Overview
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     3. Please be advised supplementally, as noted in our telephone conversation
of April 8, 2009, that the disclosure in the Registration  Statement  pertaining
to the decrease in the percentage of the Company's revenues derived from IBM has
been revised to set forth more detail as to the decrease in services provided to
IBM in Europe.

Executive Compensation
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     4. Please be advised  supplementally  that the  disclosures set forth under
Executive  Compensation  have been  revised to include  disclosure  of executive
compensation for the year ended December 31, 2008.

Exhibit 5.1
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     5. Please be advised  supplementally  that the opinion of counsel furnished
as Exhibit 5.1 has been revised to address the staff's comment.

     The Company will refrain from requesting  acceleration of the  Registration
Statement while the Company's  confidential treatment application is still under
review.


                                    Very truly yours,

                                    BECKMAN, LIEBERMAN & BARANDES, LLP

                                     /s/ David H. Lieberman
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                                    By:  David H. Lieberman