SecProbe.io

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Mail Stop 0407

      March 31, 2005

Via U.S. Mail and Fax (781-251-4655)
Mr. Keith Farrish
Vice President of Finance and Chief Financial Officer
Lojack Corporation
200 Lowder Brook Drive, Suite 100
Westwood, MA  02090

	RE:	Lojack Corporation
		Form 10-K for the fiscal year ended December 31, 2004
		Filed March 15, 2005
		File Number 1-08439

Dear Mr. Farrish:

      We have reviewed the above referenced filing 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.  Please address the following
comments in future filings.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a future
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.

Sales and Marketing, page 5

1. We note that you have entered into cooperative arrangements
with
third parties ... "to increase penetration in existing markets."
Please tell us the nature of these arrangements with third
parties.

Results of Operations, page 21

2. We note that Boomerang`s annual sales based on its last fiscal
year, as disclosed on page 17, if sustained or exceeded, may have
a
material impact on your future operations.  We also note your
disclosure in Note 2 that Boomerang was historically profitable.
If
there is a reasonable likelihood that reported financial
information
or any historical trend is not indicative of this segment`s and
your
future financial condition or future operating performance, please
provide the disclosure necessary to enable your investors to
understand how the recent acquisition will impact the quality and
potential variability of your earnings and cash flows. Refer to
Commission Guidance Regarding MD&A at
https://www.sec.gov/rules/interp/33-8350.htm.

Factors That May Affect Performance, page 31

3. We note that your Boomerang segment heavily depends on their
"alliance with wireless carriers and insurance companies" and one
of
your key business factors is to continue to "develop relationships
with insurance companies to help drive demand, where applicable."
Please tell us the nature of Boomerang`s business arrangements
with
insurance companies and wireless carriers.

Consolidated Statements of Income, page 38

4. Please separately present revenues from product, service and
other
sales and their related cost of revenues.  Refer to Rule 5-
03(b)(1)
and (2) of Regulation S-X.

Note 1. The Company and Summary of Significant Accounting Policies

Revenue Recognition and Deferred Revenue, page 41

5.  Tell us how you determine when royalty revenues are earned and
your basis for measurement.

6. Please tell us how you concluded that revenue from the sale of
LoJack Early Warning units should be deferred over five years (the
estimated life of vehicle ownership), whereas revenue from the
sale
of other LoJack units is generally recognized upon installation
and
the sale to a third party is recognized upon shipment.  Include in
your response references to the appropriate accounting literature.
Also tell us the circumstances in which you recognize revenue from
the sale of other Lojack units other than upon installation.

7. Please tell us how you concluded that the recognition of
product
revenues upon shipment to third parties is appropriate under GAAP.
Include in your response references to the appropriate accounting
literature.

8. Please tell us how you concluded that the recognition of
Boomerang
Unit product and service contract revenues is appropriate under
EITF
00-21.

9. Please tell us how you account for the premiums paid to third
parties who are the primary obligors on extended warranty
contracts
and your obligations to the third party during the policy period.

10. Please tell us if the extended warranty period is the same as
the
remaining "estimated life of vehicle ownership."  If not, tell us
why
it is appropriate to recognize the extended warranty revenue over
a
period other than the extended warranty period.

Accounts Receivable, page 43

11. Please tell us the nature of purchased private trade credit
insurance.  Also tell us how you are accounting for it and your
basis
for your accounting.  Include in your response references to the
appropriate accounting literature.

Note 9. Stockholders` Equity, page 53

12. Please tell us the terms of the Special Voting Preferred
Stock.
Also tell us how you accounted for its issuance in the financial
statements and the basis for the accounting.

Part II, Item 9A. Controls and Procedures

13.  Since it is not apparent whether your certifying officers, in
making their conclusions in your Form 10-K, considered all
information described in the definition of disclosure controls and
procedures in Exchange Act Rule 13a-15(e), please tell us in your
response letter whether your certifying officers concluded, as of
the
end of the period covered by the report, your disclosure controls
and
procedures were 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 certifying officers, to allow timely decisions regarding
required disclosure.  See Exchange Act Rule 13a-15(e).
Alternatively, you may simply state in your response letter, if
true,
that your certifying officers concluded that, as of the end of the
period covered by the report, your disclosure controls and
procedures
were effective.
Please include such conclusions in future filings, as required.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested supplemental information.  Please file your response
letter
on EDGAR.

	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 Kathryn Jacobson, Staff Accountant at (202)
824-5332 or Dean Suehiro, Senior Staff Accountant, at (202) 942-
1894
if you have questions regarding comments on the financial
statements
and related matters.  Please contact Cheryl Grant, Staff Attorney,
at
(202) 942-1916 or me at (202) 942-1990 with any other questions.

							Sincerely,

							Larry Spirgel
							Assistant Director

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Mr. Keith Farris
Lojack Corporation
March 31, 2005
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