Mail Stop 6010

      December 29, 2005

Michael S. Smith
Chief Executive Officer
Infinite Group, Inc.
595 Blossom Road, Suite 309
Rochester, New York 14610

      Re: 	Infinite Group, Inc.
      Revised Preliminary Proxy Materials
      Filed December 23, 2005
      File No. 0-21816

Dear Mr. Smith:

	We have limited our review of your filing to those issues we
have addressed in our 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 information so we may better understand
your
disclosure.  After reviewing this information, we may 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Proposal No. 3, page 12
1. Please reconcile your disclosure regarding 75,000 shares in
response to prior comment 1 with the numbers in the table on page
11.
Ensure that your response to prior comment 1 addresses all
commitments to issue shares of common stock.  For each commitment
to
issue shares in excess of the number currently authorized, provide
all disclosure required by Schedule 14A as if shareholders were
being
asked to approve the commitment.


2. Please refer to prior comment 2.  Please disclose the
following:

* specific information regarding the date of issuance, and
* reasons for issuing the notes.

3. Please refer to the seventh bullet of prior comment 2.  Please
clarify the relationship, if any, between Infinite Group and
Hampton
Holdings LLC.  Also, identify the natural person who beneficially
owns the securities held in the name of Hampton Holdings.
4. Please quantify the number of shares issuable from a proposed
conversion that may result in a change of control.

Compensation of Directors and Executive Officers, page 17
5. Please update this section for the fiscal year ended December
31,
2005.

      As appropriate, please revise 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 revised filing to expedite our review.  Please furnish a cover
letter with your amendment 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 amendment and responses
to
our comments.

      Please contact Tom Jones at (202) 551-3602 or me at (202)
551-
3617 if you have questions.


      						Sincerely,



      						Russell Mancuso
      Branch Chief


cc. Kenneth S. Rose
Via telefax (212) 838-5030

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Infinite Group, Inc.
December 29, 2005
Page 2