SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>sharp.txt
<DESCRIPTION>BURNETT: LETTER DATED 11/16/04 RE RESIGNATION OF AUDITOR RE 401(K) SAVINGS PLAN - NO 8-K FILED
<TEXT>

Mail Stop 0308

							November 16, 2004

Jeff Forgan
Chief Financial Officer
Sharper Image Corporation
650 Davis Street
San Francisco, CA  94111

	RE:	The Sharper Image 401(k) Savings Plan
		Resignation of independent auditors
            	File No. 0-15827

Dear Mr. Forgan:

          The staff has received a SECPS letter from Comyns, Smith,
McCleary & Deaver, LLP notifying the Chief Accountant of the
Commission that the registrant`s auditor/client relationship with
them has ceased.   We have the following comments as a result of that
letter.  We welcome any questions you may have about our comments.
Feel free to contact us at the telephone numbers listed at the end of
this letter.
1. The Sharper Image 401(k) Savings Plan is required to file a Form
8-K as a result of the auditor`s resignation.  Our records do not
indicate that an 8-K has been filed.  Since the Form 8-K was due
within four days of the resignation it should be filed immediately.
2. Item 304 of Regulation S-K describes the disclosure requirements
of the Item 4 Form 8-K. In order for the former accountants to file
the letter required by Item 304, a copy of the filing should be
furnished to them as soon as possible, but no later than the date you
file the Form 8-K with the Commission.  The accountants confirming
letter should be filed with an amended Form 8-K on Exhibit 16 within
two business days of receipt but no later than ten business days
after filing the Form 8-K.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filing 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.

The Sharper Image 410(k) Savings Plan
November 16, 2004
Page 2

	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
disclosures 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 this action 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 connection with our review of your
filing or in response to our comments on your filing.

 	Any questions regarding the above should be directed to me at
(202) 942-1809, or in my absence to Robert Benton at (202) 942-1811.

							Sincerely,

							Robert Burnett
						            Staff Accountant

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