SecProbe.io

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Mail Stop 6010
      October 18, 2005

By U.S. Mail and Facsimile to (631) 273-3621

Mr. Jeffrey D. Gash
Executive Vice President, Chief Financial Officer and Secretary
Jaco Electronics, Inc.
145 Oser Avenue
Hauppauge, New York 11788

      Re:	Jaco Electronics, Inc.
      Form 10-K for the fiscal year ended June 30, 2005
		File No. 2-34664

Dear Mr. Gash,

      We have reviewed your filing and have the following
comments.
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 future filings 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 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 fiscal year ended June 30, 2005

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 14

Liquidity and Capital Resources, page 22

1. We note from your disclosures on page F-18 that you entered
into a
supply agreement with Sagamore Holdings to supply electronic
components to Nexus.  Please revise Management`s Discussion and
Analysis in future filings to quantify and discuss any actual or
expected impact of this agreement on your results of operations,
liquidity and capital resources, if material.

2. Please tell us and revise future filings to define the
financial
ratios and minimum net worth levels required in your financial
covenants.  Explain what would happen if you were unable to obtain
a
waiver or amendment from your lender on reasonable terms.

Item 9A. Controls and Procedures, page 25

3. We note that your "disclosure controls and procedures are
effective to ensure that information required to be disclosed in
the
reports that the Company files or submits under the Securities
Exchange Act of 1934 is recorded, processed, summarized and
reported
within the time periods specified in the SEC`s rules and forms."
Please revise future filings to clarify, if true, that your
officers
concluded that your disclosure controls and procedures are also
effective to ensure that information required to be disclosed in
the
reports that you file or submit under the Exchange Act is
accumulated
and communicated to your management, including your chief
executive
officer and chief financial officer, to allow timely decisions
regarding required disclosure.  See Exchange Act Rule 13a-15(e).

Note B - Summary of Significant Accounting Policies, page F-9

2. Revenue Recognition, page F-9

4. We note your disclosures that "in general, revenue is
recognized
when it is realized or realizable and earned" and "revenue from
product sales is recognized generally when the product is
shipped."
Please tell us when this would not be the case.  In future
filings,
please discuss any material exceptions to your revenue recognition
policy.

5. You state that a portion of your business involves shipments
directly from your suppliers to your customers.  Please tell us if
you report all revenue at gross (as a principal) or if you act as
an
agent in certain transactions.  Discuss the consideration to the
guidance in EITF 99-19 given the price protection, stock rotation
privileges and the right to return inventory typical in your
agreements with suppliers as discussed on page 8 of your business
section.  Also, please tell us if:
* The supplier is responsible for fulfilling the ordered product
or
service, including remedies if the customer is dissatisfied.
* The company earns a fixed dollar amount per customer transaction
regardless of the amount billed to the customer.
* The credit risk is assumed by the supplier.

6. Inventories, page F-11

6. We note from your revenue recognition policy that you sell
certain
products on a consignment basis. In future filings revise your
inventory presentation to separately report the value of inventory
consigned to others at each balance sheet date.  Refer to Question
2
of SAB Topic 13(A)(2).

7. We note your provision for inventory of $6.9 million as of June
30, 2005.  Please tell us more about your inventory management
practices.  Specifically;
* Tell us how you determined the amount and timing of the write-
downs.
* Explain why this inventory is not included in the price
protection
from your suppliers.
* Explain if any of the provision relates to customized customer
orders that were cancelled or if these inventories are sold to
many
customers.
* Tell us the consideration given to the fact that sales of these
inventory items in the future could materially distort future
profit
margins.

8. Goodwill and Other Intangible Assets, page F-11

8. Please provide us with a summary of the relevant facts,
assumptions, and estimates you considered in your goodwill
impairment
analysis supporting your conclusion that no impairment of goodwill
existed at June 30, 2005. Please refer to paragraphs 19 - 22 of
SFAS
142 in your response.

9. Please expand your disclosure in future filings to specifically
identify your reporting units and the amount of goodwill for each,
as
required by SFAS 142, paragraph 45.

Note C - Discontinued Operations, page F-18

10. We note that in connection with your sale of Nexus that you
and
Sagamore Holdings are in dispute regarding the final adjustment
related to Nexus` working capital.  Please tell us the nature of
this
dispute and how you have accounted for this contingency in your
June
30, 2005 financial statements. Additionally please tell us if this
dispute has been subsequently resolved and if there have been any
post purchase price adjustments.

11. We note that you reported the sale of Nexus as discontinued
operations. Tell us how you met the criteria in paragraph 42(b) of
SFAS 144.  Specifically, please tell us why you believe the
purchase
and earn-out agreements entered into with Sagamore Holdings do not
constitute a significant continuing involvement that would
preclude
treatment of the component as discontinued operations.

`````
        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 information.  Detailed cover
letters greatly facilitate our review.  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 filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and 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 filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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 filing or in
response to our comments on your filing.

	You may contact Eric Atallah, Staff Accountant at (202) 551-
3663
or me at (202) 551-3554 regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Martin James, Senior Assistant Chief Accountant, at (202)
551-3671 with any other questions.

      								Sincerely,

								Angela Crane
								Branch Chief

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Mr. Jeffrey D. Gash
Jaco Electronics, Inc.
Page 5

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