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Correspondence Letter

 June 3, 2005

 Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, DC 20549

Re:

Cobra Electronics Corporation

Form 10-K for the Fiscal Year Ended December 31, 2004

Filed March 31, 2005

File No. 0-00511

 Ladies and Gentlemen:

 Set forth below are the comments from the staff (the “Staff”) of the Securities
and Exchange Commission (the “Commission”) with respect to the Form 10-K (the “Form 10-K”) of Cobra Electronics Corporation (“Cobra”) for the fiscal year ended December 31, 2004, as filed with the Commission on March
31, 2005, and Cobra’s response to those comments.

 Form
10-K for the Year Ended 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 was. We may have further comment.

 Response to 1

 The end-of-life inventory to which the Form 10-K referred consisted of several older models of two-way radios and 9
Band™ radar detectors, 95% of which were sold
during the first five months of 2004 and the balance of which were sold throughout the rest of

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the year. The effect on gross margin of these end-of-life inventory sales was to reduce gross margin by approximately 0.65 percentage points in 2004.
Substantially all of the products had been written down below cost to estimated net realizable value as of December 31, 2003; however, no product had been written down to zero value. As for selling prices, the actual selling prices of some products
were higher than the estimated market values, although on a weighted average basis the preponderance of selling prices were below the previously estimated values, resulting in a net reduction in gross margin as shown below:

 Estimated

 Value

 12/31/03

 Realized

 Value

 Gain (Loss)

 on Sale

 2004 Net

 Sales

 Gross

 Margin

 Impact

$2,541,000

$
1,738,000

$
(802,000
)

$
122,877,000

0.65
%

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.

 Response to 2

 The intangible assets pertaining to GPS handheld receivers are included in
Cobra’s intangible assets under “product software”. As background, the first two GPS handheld receivers were introduced in 2003, with a third model introduced late in the third quarter of 2004. After the release of the third model,
Cobra realized that consumer preferences had shifted more rapidly than anticipated and that the features included in competitors’ products were not able to be replicated by Cobra’s products. Therefore, Cobra concluded that the useful life
of this generation of GPS handheld receivers would be shorter than initially estimated and would conclude in 2005 as compared to the initial estimate of 2007.

As described in “Note 12 – Intangible Assets” of the financial statements included in the Form 10-K, the product software assets are
amortized based on the percentage of revenues generated in each reporting period to the total revenues expected over the weighted average estimated product life cycle. When, as was the case with these GPS handheld receivers, there is a reduction in
the estimated economic useful life, Cobra adjusts the amortization in the current year so that the product software asset pertaining to the specific products is fully amortized over the new remaining estimated useful life.

 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.

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 Response to 3

 Cobra accrues funds for advertising and sales promotions with our customers. The accrual is described in detail in the
Critical Accounting Policies Section of Cobra’s Form 10-K and reproduced below:

 “Advertising and Sales Promotion Accrual The reserve reflects amounts provided to retailers and distributors for advertising and sales promotions. Customer programs, agreed to at the beginning of
each year, are mainly variable programs dependent on sales and may be revised during the course of the year, based upon a customer’s projected sales and other factors, such as new promotional opportunities. Accruals are made monthly for each
customer by multiplying the customer’s estimated program accrual percentage by the customer’s actual sales. Therefore, this accrual will vary depending on a given quarter’s sales and the sales mix of customers from quarter to quarter.
In addition, should a customer significantly exceed or fall short of their planned program sales, adjustments may need to be made to the customer’s estimated program accrual percentage due to certain minimum and/or maximum sales thresholds in
the customer’s programs. Adjustments may also be necessary periodically for unused customer funds.”

 In 2003, Cobra took into income $1.2 million of unused program funds from 2002. Unused program funds occur primarily because Cobra has determined that a
customer has not satisfied the terms of the program and therefore is not entitled to the funds accrued for the program. It is Cobra’s practice to evaluate all accruals for customer programs on a quarterly basis and, upon determination that the
funds will not be required, take such accruals into income. Finalizing this determination normally takes time and, depending upon the customer and the nature and requirements of the program, can extend well into the subsequent year due to different
customer fiscal year-end dates and lengthy post-audit periods during which customers review all records of promotional activities to identify unclaimed program funds for which they might qualify. The amount that is left in accrued funds and taken
into income in any particular year varies depending on the programs and customer mix. For example, in 2001, Cobra took into income $833,000 and in 2002 Cobra took into income $195,000.

 There were similar amounts of potentially unused program funds as of December 31, 2004. As noted under
“Management’s Discussion and Analysis” in Cobra’s Form 10-Q for the first quarter of 2005, $142,000 of unused funds from 2004 was taken into income in the first quarter of 2005. There may be additional such unused funds from 2004
taken into income in subsequent quarters of 2005.

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 Critical Accounting Policies, page 12

4.
We note your disclosure in the Notes and 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.

 Response to 4

 The sales returns reserves
recorded for 2002, 2003 and 2004 were $1,807,000, $1,229,000 and $1,222,000, respectively.

 Determining the warranty reserve for new products varies depending upon whether or not it is a new product in an existing product line—for example, Citizens Band radios—or a new product in a new product
line. For a new product in an existing product line, the warranty reserve is determined as described in the Critical Accounting Policies Section under “Warranty Reserve”, i.e., by multiplying the historical return rate for the product
category by the most recent six months of unit sales of that model and the unit standard cost of that model. The only difference with a new product in a new product line is that Cobra assumes a 10% return rate until a historical return rate is
established after one year of sales. The assumed return rate of 10% is based on historical return rates for product lines currently and previously manufactured for and marketed by Cobra.

 Cobra plans to modify its Critical Accounting Policies in future filings as noted below (in bold) to expand disclosure for
the liquidation and net realizable value reserves:

 Liquidation Reserve The Company maintains a reserve representing the write-down of returned product from our customers to net realizable value. Returned inventory is either sold to various liquidators or returned to
vendors for credit against similar, new models; this decision and depends upon the estimated future demand for the models. Judgments are made as to whether various models are to be liquidated or returned to vendor and, for
the former, the liquidation prices expected to be received. The amount of the reserve is determined by comparing the cost of each unit returned to the estimated amount to be realized upon each unit’s disposition, either from returning the
unit to the vendor for credit towards the cost of new, similar product or liquidating the unit. This reserve can fluctuate significantly from quarter to quarter depending upon quantities of returned inventory on hand and the estimated
liquidation price or vendor credit per unit.

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 Net Realizable Value Reserve The Company maintains a reserve to write-down certain
inventory not previously sold to customers, except for that covered by the liquidation reserve discussed above, below cost, as necessary. The reserve includes models where it is determined that net realizable value is less than cost. Thus,
judgments must be made about which slow-moving, excess or non-current models are to be included and the estimated net realizable value; i.e., the per unit price that it is estimated can be received in the marketplace. This reserve will vary
depending upon the specific models selected, the estimated net realizable value for each model and quantities of each model that are determined will be sold below cost from quarter to quarter.

 Roll-forwards for the liquidation and net realizable reserves for the years
ended December 31, 2002, 2003 and 2004 are:

 COBRA ELECTRONICS CORPORATION
ROLL-FORWARDS ($000)

2002

2003

2004

 Reserve for Liquidation, January 1

(1,472
)

(3,188
)

(1,108
)

 Provision

(4,835
)

(4,082
)

(3,083
)

 Write-offs

3,119

6,162

3,476

 Ending Balance, December 31

(3,188
)

(1,108
)

(715
)

2002

2003

2004

 Reserve for Net Realizable Value, January 1

(1,291
)

(938
)

(812
)

 Provision

(1,654
)

(1,512
)

(1,508
)

 Write-offs

2,006

1,639

1,814

 Ending Balance, December 31

(938
)

(812
)

(506
)

 Cobra will provide
roll-forwards for the liquidation and net realizable value reserves in future filings.

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 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.

 Response to 5

 SAB 104 states that revenue for
a reporting period generally is realized or realizable and earned when all of the following criteria are met (with the reason why Cobra meets the criteria in bold):

1.
Persuasive evidence of an arrangement exists. Cobra only ships goods when it has a valid customer purchase order with a fixed schedule for delivery on or before the end of the
reporting period.

2.
Delivery has occurred or services have been rendered. As described below, Cobra has developed and employed a methodology that provides reasonable assurance that delivery has
occurred and that title and risk of loss have passed to the customer.

3.
The seller’s price to the buyer is fixed or determinable. Each customer purchase order has fixed, agreed upon prices.

4.
Collectibility is reasonably assured. Based upon Cobra’s review of each customer’s credit history, ability to pay and payment history, Cobra determines that it is
highly probable that the customer will pay the amount invoiced when due per the agreed upon terms of payment.

 The following is a discussion of why Cobra believes that it meets the second criterion for revenue recognition. As background, please note that Cobra has
over 300 customers—many of them with FOB destination terms and many of them small volume customers—with thousands of different shipping destinations. Because of inventory replenishment criteria common to customers in the consumer
electronics industry, a substantial number of shipments for these customers occur towards the end of the month with the last month of the quarter generally containing a significant amount of shipping activity. Based on these facts, Cobra determined
that it needed a methodology for estimating shipments to the customers with FOB destination terms to enable it to recognize revenue in the proper period on a timely basis without incurring significantly prohibitive costs or imposing burdensome
information requirements on Cobra’s customers or freight carriers, including requiring proofs of delivery for each shipment. Cobra’s methodology also needed to

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accommodate systems limitations while ensuring that the reported revenue was materially correct. Cobra’s systems are unable to recognize revenue in a
different period than shipments occur without manual entries that would require a cost-prohibitive effort, would be prone to errors and would not materially change reported results, as further described below.

 To establish a methodology, Cobra performed a detailed analysis of the
average time it took for nine of its larger FOB destination customers with destinations throughout the country, such as Wal-Mart and Best Buy, to receive their shipments. The result of this analysis was an average transit time of 3.5 days (rounded
up to 4 days), which Cobra now uses as a reasonable estimate of when delivery occurs, and title and risk of loss passes for a FOB destination customer. Therefore, a shipment made to an FOB destination customer more than four days prior to the end of
a reporting period is estimated to be received by the customer during that reporting period.

 A second part of Cobra’s methodology—necessitated by the systems limitations discussed above and the large volume of shipping activity toward month end—is to determine what customers will comprise at
least 80 percent of Cobra’s dollar shipments for that quarter and, consequently, those for which the revenue from shipments in the last four days of the reporting period will not be recognized. The customers identified in this 80 percent
category are the ones that Cobra reviews to determine which ones are FOB destination customers and to which this four-day window will apply. Accordingly, revenue for shipments made to these FOB destination customers during the last four days of the
month is not recognized until the following month. (The only exception for these customers is that revenue is recognized if a shipment is specifically expedited for two-day delivery during the first two days of this four-day window and a
month-end delivery date is specified in the customer’s purchase order). Revenue for