CORRESP 1 filename1.txt 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.