Mail Stop 3561
                                                            September 4, 2018

John Salerno
Chief Executive Officer
iGambit, Inc.
1050 W. Jericho Turnpike, Suite A
Smithtown, NY 11787

       Re:    iGambit, Inc.
              Information Statement on Schedule 14C
              Filed August 9, 2018
              File No. 0-53862

Dear Mr. Salerno:

       We have limited our review of your information statement to those issues
we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the
requested information or advise us as soon as possible when you will respond.
If you do not
believe our comments apply to your facts and circumstances, please tell us why
in your
response.

     After reviewing your response to these comments, we may have additional
comments.

General

1.     In your Form 8-K filed August 6, 2018, you state that your designation
and
       subsequent issuance of Series A Preferred Stock to CEO John Salerno on
August 2,
       2018 "gives him effective control over [your] affairs." Please amend
this Form 8-K
       to provide the disclosure required by Item 5.01 of Form 8-K for a change
in control,
       and also revise the instant information statement to provide the
disclosure required by
       Item 6(e) of Schedule 14A.

2.     Please make revisions throughout your information statement to make it
consistently
       clear that Mr. Salerno is the sole holder of Series A Preferred Shares
and thus holds
       the majority of your outstanding voting power. For example, please
revise your
 John Salerno
iGambit, Inc.
September 4, 2018
Page 2

       references to "the stockholders that are the record owners of our Series
A Preferred
       Stock" (page 3) and to "holders of a majority of the vote represented by
our
       outstanding shares of Series A Stock" (page 5).

Proposal 1

Amendment to our Articles of Incorporation to Increase the Common Stock of the
Corporation

Purpose and Effect of Amendment, page 4

3.     According to your June 19, 2018 press release, you have entered into a
letter of intent
       with Winpoint Health LLC which contemplates your purchase of all
outstanding
       shares and business operations of Winpoint Health in exchange for a
number of your
       common shares equal to 65% of your total common shares issued and
outstanding
       after the transaction. Please revise your information statement to
disclose this
       potential issuance of common shares to Winpoint Health shareholders as a
reason for
       the authorized share increase. Refer to Item 1 of Schedule 14C and Item
19 of
       Schedule 14A. In that regard, we note that without increasing the number
of
       authorized common shares, you would not appear to have enough authorized
and
       unissued common shares to provide Winpoint Health shareholders with
common
       shares equaling 65% of your total common shares outstanding.

4.     In addition, please provide all applicable disclosure that Item 14 of
Schedule 14A
       requires with respect to your planned acquisition of Winpoint Health or
tell us why
       you do not believe this disclosure is necessary. Refer to Item 14(a)(3)
of Schedule
       14A, which requires disclosure for "[a]n acquisition of any other going
business or
       the assets of a going business," as well as Note A to Schedule 14A,
which states that
       where "any item calls for information with respect to any matter to be
acted upon and
       such matter involves other matters with respect to which information is
called for by
       other items of this schedule, the information called for by such other
items also shall
       be given." In your expanded disclosure, please ensure you specify the
exemption
       pursuant to which you plan to issue common shares to the Winpoint
shareholders and
       equity investors, along with a brief description of the facts giving
rise to the
       availability of the exemption.

       We remind you that the company and its management are responsible for
the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
 John Salerno
iGambit, Inc.
September 4, 2018
Page 3

      Please contact Parhaum J. Hamidi, Special Counsel, at (202) 551-3421 or
me at (202)
551-3720 with any questions.


                                                         Sincerely,

                                                         /s/ Mara L. Ransom

                                                         Mara L. Ransom
                                                         Assistant Director
                                                         Office of Consumer
Products