February 19, 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 October 2, 2008
         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 October 27, 2008
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 October 27, 2008 comment  letter.  We are  providing a hard copy
blacklined version of the Registration Statement to facilitate your review

Cover Page of Prospectus
- ------------------------

     1. Please be advised  supplementally that we have revised the cover page of
the prospectus to provide an overview of all of the underwriting arrangements.

Risk Factors, page 4
- --------------------

     2. Please be advised  supplementally  that we have revised the Registration
Statement to include a risk factor  setting forth a description of the described
internal control weakness,  the reasons therefore,  its duration and the absence
of a determination as to when additional personnel needed to remedy the weakness
will be  hired.  In  addition,  the same  disclosure  has been set  forth  under
Management's  Discussion  and  Analysis of  Financial  Condition  and Results of
Operations.

Securities and Exchange Commission
February 19, 2009
Page -2-


Description of Business, page 17 and 18
- ---------------------------------------

General
- -------

     3. Please be advised  supplementally  that we have revised the Registration
Statement  to include  under the caption  "Description  of Business" on page 17,
information as to the Company's contracts with IBM and on page 18 information as
to the  Company's'  contracts with EDS and the Company's  anticipation  that the
acquisition of EDS by Hewlett Packard will not have any material negative impact
on its  business  with EDS. We will be filing as  exhibits  to the  Registration
Statement redacted copies of the Company's current contracts with IBM and EDS in
accordance with a confidential  treatment request being concurrently made to the
Securities and Exchange Commission.

Management's  Discussion  and  Analysis of  Financial  Condition  and Results of
- --------------------------------------------------------------------------------
Operations For the Six Months Ended June 30, 2008
- -------------------------------------------------

Results of Operations, page 28
- ------------------------------

General
- -------

     4. Please be advised  supplementally  that the  disclosures  throughout the
MD&A have been revised to set forth reasons for the changes in revenues from IBM
and EDS.

Exhibits
- --------

Exhibit 5.1
- -----------

     5. Please be advised  supplementally  that the opinion of counsel furnished
as Exhibit 5.1 has been revised to comply with this 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
                                            By:  David H. Lieberman