SecProbe.io

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Mail Stop 3-8

      							 May 25, 2005

By Facsimile and U.S. Mail

Mr. Gregory R. Binkley
President and CEO
The Sportsman`s Guide, Inc.
411 Farwell Avenue South
St. Paul, MN 55075

      Re:    The Sportsman`s Guide Inc.
      	Form 10-K/A for the Year Ended
      	December 31, 2004
      	Filed May 12, 2005
        File No.  0-15767

Dear Mr. Binkley:

	We have reviewed your response dated April 29, 2005 to our
comment letter dated March 25, 2005 and have the following
additional
comment.   Please understand that the purpose of our review 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.  Feel free
to
call us at the telephone numbers listed at the end of this letter.
Form 10-K/A for the Year Ended December 31, 2004

Note A-3 Revenue Recognition, page 31

1. We note your response to prior comment 3 and continue to
believe
your revenue recognition policy is inconsistent with SAB 104.  We
view the Buyer`s Club membership fee to be analogous to refundable
fees for services as discussed in Question 1 of SAB Topic 13A4.
Question 1 permits you to recognize revenue applying either a SFAS
No. 48 or SFAS No. 140 based accounting model.  Under the SFAS 48
model, a portion of membership fees received will be deferred as
an
estimate of future refunds based on a homogeneous pool of
customers,
and recorded as a monetary liability.  The monetary liability will
be
reduced at the earlier of refunds given or membership expiration.
The remaining membership fees are recorded as deferred revenues in
a
non-monetary liability account and recognized straight-line over
the
remaining membership term.  Changes in the estimated level of
future
refunds are reclassified between the monetary liability and
deferred
revenue.

Alternatively, you may apply a model akin to SFAS No. 140, whereby
individual customer membership fees are received and accounted for
as
a monetary liability.  The liabilities may be derecognized only
when
you are relieved of your refund obligation or released from your
contractual service obligation.  As individual customers purchase
products the non-refundable portion of the monetary liability is
reclassified to deferred revenue and recognized straight-line over
the future remaining membership term from the point of purchase.
The
reclassification will occur successively as purchases occur until
the
entire fee is reclassified as deferred revenue. In either
accounting
model, membership fees become fixed when a membership term expires
and existing monetary liabilities and deferred revenue are
recognizable immediately.

If you adopt one of these models for recognizing revenues
associated
with refundable fees for services, please restate your financial
statements providing  the disclosures required by paragraphs 36
and
37 of APB 20 and file an amendment to your Form 10-K.  If you
select
one of the above models as a suitable method and determine the
effects of this change in accounting estimate has an immaterial
effect on your consolidated net revenues, net income and trend in
earnings, please demonstrate to us your consideration of
immateriality by including a schedule contrasting the effects of
your
current accounting estimates, gross of refunds, with the effects
of
either model.   Use a retrospective approach in the schedule and
account for effects in the current period of change and future
periods if it affects both.

If you conclude the change in accounting estimate is immaterial in
the current period but reasonably certain to have a material
effect
in later periods (i.e. increases in membership enrollment, member
fees, etc.) disclose this conclusion in the period of change. If
you
decide not to apply either of the models mentioned above, please
disclose that your accounting policy does not comply with GAAP,
that
your results would not be materially different if you recorded
Buyer`s Club membership fees in accordance with GAAP and disclose
the
immaterial difference for each income statement presented.

Irregardless of your decision, SAB Topic 13A4 also requires you to
disclose the following for each income statement presented:
* The unearned revenue and refund obligations as of the beginning
of
each period;
* The amount of cash received from customers;
* The amount of revenue recognized in earnings;
* The amount of refunds paid;
* Other adjustments (with an explanation thereof); and
* The ending balance of unearned revenue and refund obligations.

In your response please show us what your revised disclosures will
look like.

	Please send us your response to our comment within 10
business
days from the date of this letter or tell us when you will provide
us
with a response.  Please understand that we may have additional
comments after reviewing your response to our comment.  Your
supplemental response letter should be submitted in electronic
form
on EDGAR as a correspondence file.  Refer to Rule 101(a) of
Regulation S-T.

		If you have any questions regarding our comments, please
direct them to Brian V. McAllister at (202) 551-3341 or, Donna Di
Silvio at (202) 551-3202, or in her absence to the undersigned at
(202) 551-3841.

									Sincerely,

									Michael Moran
									Accounting Branch
Chief
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Mr. Gregory R. Binkley
The Sportsman's Guide, Inc.
May 25, 2005
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