SecProbe.io

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                                                                   June 01, 2005

Jean Yu
Staff Accountant
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

RE:  P.A.M. Transportation Services, Inc. (the "Company")
     Form 10-K for the fiscal year ended December 31, 2004
     File No. 0-15057

NOTE 1 - ACCOUNTING POLICIES
----------------------------
- REVENUE RECOGNITION, PAGE 36
------------------------------

1.     WE  NOTE YOUR RESPONSE TO OUR PRIOR COMMENT NUMBER THREE.  PLEASE CLARIFY
YOUR  REVENUE  RECOGNITION  POLICY  IN FUTURE FILINGS TO SPECIFICALLY STATE THAT
EXPENSES  RELATED  TO  FREIGHT  IN  TRANSIT AT THE END OF A REPORTING PERIOD ARE
RECOGNIZED AS INCURRED.

RESPONSE
--------
The  disclosure  regarding  revenue recognition was changed in the Form 10-Q for
the quarter ended March 31, 2005 to read as follows:

"Revenue  Recognition. Revenue is recognized in full upon completion of delivery
to  the  receiver's  location.  For freight in transit at the end of a reporting
period,  the  Company recognizes revenue prorata based on relative transit miles
completed  as  a  portion  of  the  estimated  total transit miles. Expenses are
recognized as incurred."

NOTE 18 - ACQUISITIONS, PAGE 50
-------------------------------

2.     WE NOTE YOUR RESPONSE TO PRIOR COMMENT NUMBER SIX AND THE REASONS WHY YOU
BELIEVE THAT INTANGIBLE ASSETS WHICH REQUIRE RECOGNITION APART FROM GOODWILL DID
NOT  EXIST AT THE TIME OF ACQUISITION. REFERENCE IS MADE YOUR RESPONSE REGARDING
CUSTOMER  BASE.  WE  NOTE THAT YOU DETERMINED THAT THE CUSTOMER BASE ACQUIRED IN
CONNECTION  WITH  THE ACQUISITION OF EAST COAST TRANSPORT, INC. DID NOT MEET THE
CRITERIA FOR RECOGNITION APART FROM GOODWILL BASED UPON THE GUIDANCE OUTLINED IN
PARAGRAPH  B165  OF  SFAS  NO.  141,  WHICH  IS ALSO PREMISED ON THE VIEW THAT A
CUSTOMER  BASE IS A GROUP OF CUSTOMERS THAT ARE NOT KNOWN OR IDENTIFIABLE TO THE
ENTITY  (SUCH  AS  CUSTOMERS  OF  A  FAST-FOOD  FRANCHISE). WE NOTE ALTHOUGH THE
CUSTOMERS  ARE  NOT  BOUND  BY  CONTRACTS,  EACH  CUSTOMER  ORDER  IS NEGOTIATED
INDIVIDUALLY  WHICH APPEARS TO INDICATE THAT THE NATURE OF THE BUSINESS REQUIRES
THE CUSTOMER TO BE KNOWN AND IDENTIFIABLE. THIS IS FURTHER SUPPORTED BY THE FACT
THAT  YOU  ALSO  ACQUIRED  A  CUSTOMER  LIST AS PART OF THE ACQUISITION. IN THIS
REGARD,  PLEASE  TELL US HOW YOU CONSIDERED THESE FACTORS IN DETERMINING WHETHER
CUSTOMER-RELATED INTANGIBLE ASSETS (I.E. NON-CONTRACTUAL CUSTOMER RELATIONSHIPS)
SEPARATE  FROM  GOODWILL EXISTED AT THE TIME OF ACQUISITION. WE MAY HAVE FURTHER
COMMENT UPON RECEIPT OF YOUR RESPONSE.

RESPONSE
--------

CUSTOMER LIST
-------------

In  our  response to the SEC Comment Letter dated March 31, 2005 we discussed an
electronic  customer list acquired with the assets of East Coast Transport, Inc.
("East  Coast").  This  discussion  noted  that  the  acquired  list is strictly
confidential  and  would  not  be  sold,  leased, or otherwise exchanged with an
external  entity  and  was therefore dismissed from consideration for separation
from  goodwill.  This response was specific to our consideration of the customer
list and was based on SFAS 141, paragraph A18.

The  acquired  customer  list  consisted  of  a database master record for every
customer  for  which East Coast had performed services during the period of time
between  their  installation  of  the  pre-acquisition software system and their
purchase  by the Company.  This master record, as well as the software, were not
utilized  by East Coast post acquisition, and had no value to the Company.  None
of  the  pre-acquisition  records,  computerized  or paper, were migrated to the
post-acquisition  system.  The  pre-acquisition  system,  including the customer
list, was abandoned at acquisition.

You  request that we discuss our consideration of customer base as an intangible
asset apart from goodwill further, as these customers are known and identifiable
to us, as is supported by the acquired customer list.  Additional considerations
surrounding  customer relationships and related customer base is provided below.

CONTRACTUAL CUSTOMER RELATIONSHIPS
----------------------------------

The  Company  utilized  the  guidance of SFAS 141, as well as, EITF No. 02-17 to
determine the possible existence of contractual customer relationships and found
that  the  nature  of  the  services  provided  by  East  Coast do not result in
agreements  that  might  be  interpreted to represent contractual relationships,
such  as  supplier  contracts,  service contracts, or purchase orders.  Services
generally  result from a verbal communication between East Coast and a potential
customer on an as needed basis when the customer determines that it will utilize
the services of East Coast.  A backlog of customer orders for transportation did
not exist and was not acquired with the assets of East Coast.

                                        2
<PAGE>

NON-CONTRACTUALCUSTOMER RELATIONSHIPS
-------------------------------------

The Company initially began its evaluation of customer relationships by breaking
down  the  criteria  for  recognition  of intangible assets apart from goodwill.

Separability
------------
The second sentence in SFAS 141, paragraph 39 provides,

"If an intangible asset does not arise from contractual or other legal rights,
it  shall  be recognized as an asset apart from goodwill only if separable, that
is,  it  is  capable  of being separated or divided from the acquired entity and
sold,  transferred,  licensed, rented, or exchanged (regardless of whether there
is an intent to do so.)

In our evaluation of separability, we considered the following circumstances:

CONTRACTUAL CUSTOMER RELATIONSHIPS
----------------------------------

East Coast had no contracts with customers.

NON-CONTRACTUAL CUSTOMER RELATIONSHIPS
--------------------------------------

The Company initially began its evaluation of customer relationships by breaking
down the criteria for recognition of intangible assets apart from goodwill.

Separability
------------
The second sentence in SFAS 141, paragraph 39 provides,

"If  an  intangible asset does not arise from contractual or other legal rights,
it  shall  be recognized as an asset apart from goodwill only if separable, that
is,  it  is  capable  of being separated or divided from the acquired entity and
sold,  transferred,  licensed, rented, or exchanged (regardless of whether there
is an intent to do so.)

In our evaluation of separability, we considered the following circumstances:

-- Capable of being separated  -
     -  The  customer  relationships  that  existed at acquisition date were the
        result  of  the historical market experience of the customer base. There
        is  virtually  no allegiance of customers to a particular transportation
        broker,  and repeat business typically results from the expertise of the
        company  in  being able to provide the required service at a lower price
        than competition in the market (both transportation brokers and trucking
        companies).
     -  While  some customers utilized the services of East Coast on a recurring
        basis, others used their services based on factors such as:
         -  Supplemental  use  of  East  Coast Transport, Inc. while negotiating
            contracts with long term carriers or brokers
         -  Transportation  needs surpassing the service capacity of traditional
            or contractual carriers/brokers
         -  To  take  advantage  of short term market price declines over agreed
            upon rate obligations with contracted carriers/brokers
         -  Seasonal  transportation  requirements  that  do  not  provide  the
            customer  leverage  to  negotiate long term contracts with permanent
            carriers/brokers
         -  Non-recurring transportation needs
     -  Recurring  customers  that  provided  a substantial portion of the total
        pre-acquisition  revenue  of  East Coast Transport, Inc. existed, but in
        interviews  with  the  previous owner of East Coast Transport, Inc., the
        composition  of  this  group,  and  the  revenue individually from each,
        historically  fluctuated from very little or no sales in some periods to
        greater  usage  in other periods based on the criterion in the preceding
        bullet  paragraph, rendering little confidence on the part of East Coast
        or the Company as to assurance of future service provision or cash flows
        from each with an acceptable degree of confidence.

-- and  sold,  transferred, licensed, rented, or exchanged (regardless of intent
   to do so)

                                        3
<PAGE>

     -  Recurring  business relationships of East Coast Transport, Inc. resulted
        from  their  ability  to provide the required transportation services to
        the  satisfaction  of  the  customer based on such criteria as price, on
        time  pickup  and delivery, convenience, and delivery of product without
        damage
     -  Each customer shops prices to obtain the most competitive price
        available in the market for particular shipments,  with price and the
        service elements  mentioned above being the primary reason for selection
        of East Coast

Although  the Company concluded the absence of any seperability criteria for the
customer base, as an additional consideration the Company examined the valuation
of  the  non-contractual  customer  relationships,  assuming  the  seperability
criteria  were  to  be  met.  East Coast's historical operating activity employs
agents  who take calls from entities (shippers) who have a product at a location
and  need  to  have  it  moved  to another location.  Shippers want to get their
product to the destination as economically and timely as possible.  They have no
preference  as  to  which  carrier  ships  the  load  or what broker they use to
facilitate  the  movement - they simply want it to be cost effective and timely.
In  this  regard,  the broker becomes only a contact point - one who facilitates
the  cost  effective/timely goal - to get the shipper's product moved.  There is
no contract created, no purchase order completed; only a verbal communication to
the  shipper  specifying  the  price the shipper will pay East Coast and another
verbal  communication  to  the selected trucker indicating the amount East Coast
will  pay  the  trucker  for  delivery  of  the shipper's product accompanied by
location and destination information.  The shipper may or may not ever call East
Coast  again.  Thus  the  nature  of East Coast's business - non-contractual and
price/time  sensitive  coupled  with the absence of customer loyalty - makes any
intangible  of  value  the  intangible  represented  by  an assembled workforce.

Conclusion
----------

Based  on  the  above  considerations,  we  concluded  that  the  acquired
non-contractual  customer  relationships were not capable of being separated and
could  not  be  sold,  transferred,  licensed,  rented or exchanged, even if the
intent to do so were assumed to exist.

Unlike  the  example  provided  in  SFAS 141, paragraph A21 regarding a commonly
exchanged  item such as deposit accounts, sales, transfers, rental, or exchanges
of transportation customer relationships had not occurred in the history of East
Coast and is not common in the industry.

We  conclude  that  the  nature of the customer relationships acquired represent
characteristics  that  are  more  consistent  with the SFAS 141, paragraph B102,
component  three regarding core goodwill provided by the combination of existing
assets  (predominantly  the  workforce  in place) that exist within the acquired
company.  We  also  believe  that  component  four  regarding expected synergies
gained  through the acquisition is very applicable and will only strengthen East
Coast's ability to attract customers (both recurring and new).

3.     WE  NOTE  YOUR RESPONSE REGARDING BROKERAGE AGENTS. PLEASE SUPPLEMENTALLY
EXPLAIN  IN  FURTHER  DETAIL  WHY YOU BELIEVE YOUR AGENT RELATIONSHIPS REPRESENT
WORKFORCE IN PLACE.

                                        4
<PAGE>

TELL  US  THE  RELEVANT  GUIDANCE  WHICH  SUPPORTS  YOUR  POSITION. FURTHER, YOU
DISCLOSE  THAT  DUE  TO  THE  OPEN  NATURE  OF  THE  AGREEMENTS  WHICH ALLOW FOR
TERMINATION  WITHOUT  PENALTY  OR  INDEFINITE EXTENSION MADE THE ESTIMATION OF A
USEFUL  LIFE EXTREMELY UNCERTAIN. HOWEVER, PARAGRAPH B174 OF SFAS NO. 141 STATES
THAT  A  PRESENT  VALUE TECHNIQUE MIGHT OFTEN BE THE BEST AVAILABLE TECHNIQUE TO
ESTIMATE  THE  FAIR  VALUE  OF  AN ACQUIRED INTANGIBLE ASSET, AND SUCH TECHNIQUE
REQUIRES  JUDGMENT  IN  ESTIMATING  THE PERIOD AND AMOUNT OF EXPECTED CASH FLOWS
WHICH  INCORPORATES  ASSUMPTIONS  SUCH  AS  FUTURE  CONTRACT  RENEWALS AND OTHER
BENEFITS THAT MIGHT RESULT IN ACQUISITION RELATED SYNERGIES. IT ALSO STATES THAT
PAST  HISTORY OFTEN PROVIDES EVIDENCE THAT THE CONTRACTS OR RIGHTS ARE GENERALLY
RENEWED  WITHOUT  SUBSTANTIAL  COST  AND  EFFORT.  TELL  US  HOW  YOU CONSIDERED
PARAGRAPH  B174  OF  SFAS  NO.141  IN  DETERMINING  WHETHER  AN INTANGIBLE ASSET
SEPARATE  FROM  GOODWILL  SHOULD BE RECOGNIZED FOR CONTRACTS WITH SUCH BROKERAGE
AGENTS. WE MAY HAVE FURTHER COMMENT UPON RECEIPT OF YOUR RESPONSE.

RESPONSE
--------

Contractual or Legal
--------------------
The first sentence in SFAS 141, paragraph 39 provides,

 "An  intangible asset shall be recognized as an asset apart from goodwill if it
arises from contractual or other legal rights "

There  were no agreements with brokerage agents prior to the acquisition of East
Coast.  Brokerage agreements were put into place at the request of the agents as
a  result  of  the acquisition to protect the agents who were concerned that the
change  of  ownership  of  East  Coast  might  cause changes in the relationship
between  the  agents  and  East  Coast.  The  relationships  with the East Coast
brokerage  agents  generally have termination clauses permitting the agent under
written  agreement to terminate the agreement upon 90 days notice to East Coast.
Additionally,  the  agreements  protect the agent by specifying the income he or
she  is  to  receive  based  on the revenue earned for the Company.  Much of the
business  of  East Coast is conducted by employees that perform the same service
as  the  agents.  Consequently, the contracts with the agents have little value,
and  certainly  no  long-term  value,  to  the Company beyond a normal assembled
workforce arrangement.

Conclusion
----------
Based  on the absence of any contractual relationships prior to acquisition, and
the  terms  of  the  subsequent agreements only requiring an agent to stay for a
period  of  90 days and the uncertainty of the fair value of replacement cost of
agents,  cost  to  hire and train and related intellectual capital, we concluded
that  the  East Coast agents represented assembled workforce in place and should
be  included  in  the  amount  initially  recorded  in  goodwill.

SCHEDULE 14A PROXY STATEMENT
----------------------------
COMPENSATION COMMITTEE INTERLOCKS AND INSIDER PARTICIPATION
-----------------------------------------------------------

4.  THE  DISCUSSION  ON  PAGE  7  OF YOUR SCHEDULE 14A PROXY STATEMENT REGARDING
TRANSACTIONS  WITH  CERTAIN  ENTITIES AFFILIATED WITH YOUR EXECUTIVE OFFICERS IS
INCONSISTENT  WITH THAT PROVIDED

                                        5
<PAGE>

IN  NOTE  7  TO  YOUR  AUDITED  FINANCIAL  STATEMENTS. IN FUTURE FILINGS, PLEASE
RECONCILE AND REVISE THESE DISCLOSURES

Response
--------

Future  disclosures regarding related party transactions will be reconciled, and
consistent.

Respectfully,

/S/ Larry J. Goddard
--------------------

Larry J. Goddard
Chief Financial Officer
P.A.M. Transportation Services, In