SecProbe.io

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Mail Stop 0407

      April 8, 2005

Mr. Michael Smith
Senior Vice President and Chief Financial Officer
Cobra Electronics Corporation
6500 West Cortland Street
Chicago, IL  60707

	RE:	Cobra Electronics Corporation
		Form 10-K for the fiscal year ended December 31, 2004
		Filed March 31, 2005
		File No. 0-00511

Dear Mr. Smith:

      We have reviewed the above filings and have the following
comments.  We have limited our review to only your financial
statements and related disclosures and will make no further review
of
your documents.  As such, all persons who are responsible for the
adequacy and accuracy of the disclosure are urged to be certain
that
they have included all information required pursuant to the
Securities Exchange Act of 1934.  Where indicated, we think you
should revise your documents 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 supplemental 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 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.

Form 10-K for the year ending December 31, 2004

Results of Operations, page 9

1. We note your disclosure that gross margin decreased due to the
sale of certain end-of-life inventory.  Clarify for us when these
products were actually sold and quantify the impact on gross
margin.
Specifically tell us whether these units had been written down to
zero and what the selling price later was.  We may have further
comment.

2. We note your discussion that the estimated useful economic life
was changed for certain handheld GPS models.  Please provide us
with
more details including whether these amounts are included in the
caption "product software," and how it was determined that the
useful
life needed to be shortened given that these products appear to
have
been introduced in 2003.

2003 Compared to 2002, page 10

3. We note your disclosure of the reversal of $1.2 million of
unused
program funds from 2002.  It appears these amounts were taken into
income in 2003.  Tell us what these funds are related to, why they
were not used in 2002 or 2003 and whether you have accrued any
similar amounts as of December 31, 2004.

Critical Accounting Policies, page 12

4. We note your disclosure in the Notes and the Critical
Accounting
Policies about your sales returns, warranty and inventory
reserves.
Please provide us with more details about the following:

* Tell us the amounts recorded for the sales returns reserves for
2002, 2003 and 2004.

* Tell us how you determine the warranty reserve for new products.

* Expand your disclosure regarding the amounts for the liquidation
reserve and net realizable value reserve and provide a rollforward
of
these amounts in a manner similar to the warranty reserve
activity.

Financial Statements

Note 1 - Summary of significant accounting policies, page 21

      Revenue recognition, page 23

5. It is unclear to us why you recognize revenue based on an
estimated average shipping time for certain customers.  Tell us
why
you believe that your revenue recognition policy is in accordance
with SAB 101 as amended by SAB 104.

6. Confirm that you recognize revenue for all customers when title
and risk of loss pass to the customer.

Note 7 - Stock option plans, page 28

7. We note that the consideration received by the company upon
exercise of the options may be paid in cash or by the surrender
and
delivery to the company of previously owned shares of your common
stock or by a combination both.  For those options granted after
the
issuance of FIN 44 tell us how you concluded that variable
accounting
was not required in view of the stock for stock feature described
above.

Note 10 - Loan Receivable, page 30

8. Tell us about your business relationship with Horizon
Navigation,
Inc., including but not limited to  the business purpose of
granting
the loan to Horizon Navigation, Inc.  Tell us why you pay
royalties
to Horizon and the amounts paid for 2002, 2003 and 2004.

9. We note your discussion in Note 17 of the warrants received
from
Horizon Navigation, Inc. and your planned assessment of whether
this
entity should be accounted for under the equity method.  Tell us
the
conclusions you reached in regard to this assessment, and also
tell
us how you evaluated this entity under FIN 46R.

Note 11 - Segment Information, page 30

10. Revise your filing to provide additional disclosure about
revenues for individual products and services consistent with
paragraph 37 of SFAS 131.

Note 12 - Intangible Assets, page 31

11. We note your discussion of your amortization of software
related
to products to be sold.  Tell us how you consider new product
introductions in determining if impairment exists, as it appears
from
your discussion in the Business section that certain new products
may
be introduced as upgrades to products for which you may have
capitalized software costs.  Additionally, it appears that your
review for impairment may not be as frequent as required by
paragraph
10 of SFAS 86.  Revise or advise.

Note 16 - Allowance for Claims and Doubtful Accounts, page 33

12. Revise your filing to describe the program of insurance
coverage
on accounts receivable in more detail.  Specifically disclose the
premiums paid for this coverage and where these amounts are
captured
in the Consolidated Statement of Earnings.  If you have collected
under these policies, tell us the amounts you have received in
each
of the three years.

Note 17 - Subsequent Events, page 33

13. Tell us why you maintained insurance coverage on a former
executive of the Company.  Also, tell us and disclose if
collection
of these amounts under your existing policy will have any impact
on
future premiums.  Finally, we note you disclose that the value of
this policy at December 31, 2004 was $4 million.  Tell us and
consider disclosing which executives the remaining balances relate
to, and tell us whether these are all current executives.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your 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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments 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 our review of your filings or
in
response to our comments on your filings.

      You may contact Kathleen Kerrigan, Staff Accountant, at
(202)
942-1944 or Ivette Leon, Assistant Chief Accountant, at (202) 942-
1982 if you have questions regarding these comments.

							Sincerely,

							Larry Spirgel
							Assistant Director

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Mr. Michael Smith
Cobra Electronics Corporation
April 8, 2005
Page 3 of 5

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