Room 4561

	January 24, 2006

Mr. Gene M. Bauer
Corporate Secretary
Globix Corporation
139 Centre Street
New York, New York 10013

Re:	Globix Corporation
	Preliminary Information Statement on Schedule 14A filed
January
17, 2006
	File No. 1-14168

Dear Mr. Bauer:

      This is to advise you that we have limited our review of the
above filing to the matters addressed in the comments below.  No
further review of the filing has been or will be made.  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 any other aspect
of
our review.   Feel free to call us at the telephone numbers listed
at
the end of this letter.

Preliminary Information Statement on Schedule 14A

Proposal Two - Amending the Stock Option Plan, page 29

1. We note your discussion of options granted in September 2005
and
the specific option granted to Mr. Ted S. Lodge to induce him to
become your chairman of the board and executive chairman.  Please
provide disclosure pursuant to Items 10(a)(2) and (b)(2) of
Schedule
14A with respect to the amended plan and the specific grants under
the plan, respectively.  Further, per your disclosure that the
options granted in September 2005 are subject to stockholder
approval, it would appear that the specific grants under your plan
in
excess of the number of shares authorized under the current plan
should be set forth as a separate proposal to stockholders with
disclosure pursuant to Item 10(b)(2).  Your current proposal
relates
principally to amending your plan to increase the number of shares
authorized and the per individual grant limit.  Please advise or
revise, as appropriate.


*              *              *              *


      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses 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 amendments and
responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings includes all information required under the Exchange Act
and
that they have provided all information investors require for an
informed investment 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.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      You may contact Daniel Lee at (202) 551-3477, or Anne
Nguyen,
Special Counsel, at (202) 551-3611, with any questions.  If you
need
further assistance, you may contact me at (202) 551-3730.

	Sincerely,


	Barbara C. Jacobs
	Assistant Director

cc:	Via Facsimile
	Bonnie J. Roe
      David Tyler
	Day, Berry & Howard LLP
	875 Third Avenue
      New York, New York 10022
	Telephone: (212) 829-3600
	Facsimile:  (212) 829-3601