Mail Room 4561

								July 26, 2006

James M. Powers, Jr.
Chairman of the Board, President and
   Chief Executive Officer
iLinc Communications, Inc.
2999 North 44th Street, Suite 650
Phoenix, Arizona 85018

	Re:   	iLinc Communications, Inc.
		Registration Statement on Form S-3
		Filed on July 6, 2006
		File No. 333-135623

Dear Mr. Powers:

      We have limited our review of the above-referenced Form S-3
registration statement of
iLinc Communications, Inc. to the disclosure items identified
below
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 additional 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 welcome any questions you may have about our comments or on any
other aspect of our review and look forward to working with you.
Feel free to call us at the telephone numbers listed at the end of
this letter.

Selling Stockholders, page 8
1. Please revise the disclosure in the footnote relating to Herald
Investment Trust PLC to clarify whether Fraser Elms, who is the
fund
manager, also exercises sole voting and dispositive power over the
selling shareholder.

Plan of Distribution, page 14
2. Your discussion regarding the use of supplements indicates that
you will set forth in a supplement "the number of shares to be
sold,
the purchase price and public offering price, any new selling
stockholders (who will be limited to stockholders who acquire
shares
. . . from persons named as selling stockholders in this
prospectus)
...."  Please be advised that the addition or substitution of
selling
shareholders by prospectus supplement may not involve increasing
the
number of shares or dollar amount registered and is limited,
consistent with your disclosure, to transferees, pledgees and
donees
of identified selling securityholders at the time of effectiveness
of
the registration statement.  Please revise accordingly.  In
addition,
please clarify that information regarding unnamed selling
securityholders at the time of effectiveness must be provided
using a
post-effective amendment.  Please refer to interpretation B.81.
relating to the Securities Act Rules of the Corporation Finance
Manual of Publicly Available Telephone Interpretations, which is
publicly available on our website.

Where you can find more information, page 16
3. Please note that the Commission is now located at 100 F Street
NW,
Washington, D.C.  20549.
4. In your next amendment, please specifically incorporate by
reference the Form 8-K filed on July 6, 2006.

Part II
Undertakings
5. The undertakings required by Item 512(a) of Regulation S-K have
recently been updated.  Please update the disclosure to include
the
currently required undertakings outlined in paragraph (a)(5)(i) or
(ii), as appropriate.

Legality Opinion
6. Please confirm that the reference and limitation in the opinion
to
"the General Corporation Law of the State of Delaware" includes
the
statutory provisions and also all applicable provisions of the
Delaware Constitution and reported judicial decisions interpreting
these laws.

Signatures
7. We note that Mr. James L. Dunn signed the registration
statement
in his capacity as Senior Vice President and Chief Financial
Officer
(Principal Financial Officer).  Please also identify the person
signing in the capacity of controller or principal accounting
officer
as required by the instructions to signatures to Form S-3. See
also
Section 6(a) of the Securities Act.

      As appropriate, please amend your filings in response to our
comments.  You may wish to provide us with marked copies of the
amendments to expedite our review.  Please furnish a cover letter
with your amendments that keys your responses to our comments and
provides any requested 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 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.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* 	  should the Commission or the staff, acting pursuant to
delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to
the
filing;

*	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* 	the company may not assert this action 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.

      We will consider a written request for acceleration of the
effective date of the registration statements as a confirmation of
the fact that those requesting acceleration are aware of their
respective responsibilities under the Securities Act of 1933 and
the
Securities Exchange Act of 1934 as they relate to the proposed
public
offering of the securities specified in the above registration
statements.  We will act on the request and, pursuant to delegated
authority, grant acceleration of the effective date.

      We direct your attention to Rule 461 regarding requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendments 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.

      Please direct all questions to Maryse Mills-Apenteng at 202-
551-3457.  If you still require further assistance, please contact
the undersigned at 202-551-3730.

								Sincerely,



      			Barbara C. Jacobs
      			Assistant Director

cc:  	Via facsimile:  (214) 661-6606
	James S. Ryan, Esq.
	Jackson Walker LLP

James M. Powers, Jr.
iLinc Communications, Inc.
July 26, 2006
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