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[Letterhead of Thomas A.
Mutryn]

June 30, 2005

BY EDGAR AND FACSIMILE

Craig Wilson, Senior Assistant Chief Accountant

Division of Corporation Finance

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549-0406

Re:                               GTSI
Corp.’s Form 10-K for the Fiscal Year

Ended December 31, 2004 (File No. 000-19394)

Dear Mr. Wilson:

On behalf of GTSI Corp. (“GTSI” or the “Company”), I am providing this
letter in response to the comments of the Commission’s staff set forth in your
letter dated June 3, 2005 regarding the Company’s annual report on Form 10-K
for the fiscal year ended December 31, 2004 (File No. 000-19394)
filed with the Commission on March 16, 2005 (the “2004 Form 10-K”).  To aid in the staff’s review, I have repeated
the staff’s comments followed respectively by the Company’s responses.

Form 10-K:  For the year ended December 31, 2004

Item 1.
Business

Business Strategy, p. 4

1.                                      While
we note your response to our prior comment 1, it does not appear that you have
any specific information supporting the notion that revenues may be doubled
over the next three years.  For example,
most of the excerpts from your 10-K provided in support of this statement
merely discuss steps you have taken in the hope of expanding your business and
revenues without providing any true support for the statement.  Additionally, even where you have quantified
past increases in revenues, such as your disclosure regarding an increase in
sales from services, such increases appear to relate to portions of your
business that comprise only a small percentage of total revenues and/or
increases that are not large enough to support doubling your revenues over the
next three years.  Furthermore, while we
note your statement that an increase from your current 1% of the government IT
budget to just 2% would enable the Company to reach its strategic revenue goal,
it is unclear why you believe you will double your percentage of the government
IT budget.  For example, it does not
appear that you have entered into any new government contracts.  Please provide additional supplemental
support for your strategic revenue goal or revise as appropriate.

In the beginning of 2004, the Company
reviewed its historical financial performance in conjunction with a competitive
market analysis, and concluded that GTSI held only a small percentage of market
share in a highly fragmented, growing government IT market.  As a leader in the government IT market, GTSI’s
management team believed that the Company could

1

substantially increase its revenue growth by
hiring additional sales people to penetrate areas of the government IT market
that had previously been underserved.
The Company believed there was a direct linkage between the number of
salespeople within its organization and its potential revenue growth.  The Company incorporated this concept into an
ambitious strategic growth plan with a goal to increase market share and to
double sales of the Company to $2 billion, principally through organic
initiatives, by 2007.

A financial plan was developed detailing
incremental milestones for annual revenue growth, gross margin improvement, and
net income targets for 2005 through 2007.
This plan was presented to GTSI’s Board of Directors in July 2004.  Upon consideration by the Board, the
financial plan was approved and deployed Company wide. Additionally, several
key executives were awarded substantial compensation increases to support these
growth initiatives, and an ambitious executive incentive compensation plan for
2006 and 2007 was instituted based on the achievement of the Company’s
financial targets. This document was filed as Exhibit 10.19 to the 2004 Form 10-K.
Aggressive hiring practices commenced immediately upon approval of the plan.

Summary from Strategic Plan (dollars in thousands)

  2004

  2005

  2006

  2007

  Sales

  $

  1,103

  $

  1,456

  $

  1,954

  $

  2,247

  Gross Margin

  $

  85

  $

  128

  $

  186

  $

  223

  Gross Margin
  %

  7.72

  %

  8.82

  %

  9.51

  %

  9.91

  %

  Net Income

  $

  5

  $

  6

  $

  19

  $

  28

  Average
  headcount

  758

  1118

  1476

  1524

Management’s disclosure of its strategic growth plan in its 2004 Form 10-K
was intended to provide readers and investors with additional forward-looking
disclosures based on management’s anticipation of future trends in government
IT spending increases, and its anticipation that the impact of increasing GTSI’s
headcount would result in increased revenues for the Company.

While it is true that the Company has not entered into any material new
government contracts since September 2003, the Company’s business model is
not dependent upon contract awards. Unlike government contractors or IT service
providers who recognize revenue based on contracts, GTSI contracts are merely
vehicles through which government customers may procure IT hardware and
software products. The indefinite delivery/indefinite quantity nature of GTSI’s
contracts allow the Company to earn revenue based on the quantity of products
delivered to customers, not the quantity of contracts.

In summary, from the inception of GTSI’s three year strategic growth
plan in 2004 until the receipt of its financial results as of March 31,
2005, the Company’s management had every indication that increasing the size of
its workforce would result in significantly increased sales. GTSI disclosed an
overview of its strategic plan to double sales to investors in its 2004 Form 10-K
as additional forward looking information in an effort to increase the
transparency of the Company’s objectives and goals and facilitate investors
viewing GTSI through the eyes of its management team.

2.                                      As
a follow-on to the comment above, we note from your Form 10-Q for the
quarter ended March 31, 2005 that your total first quarter revenue was “weaker
than [you] expected,” and actually declined by $21.6 million compared to the
three months ended March 31, 2004.
We also note that you continue to disclose that you are “seeking to
double revenues to $2 billion.”

2

Tell us if you are currently on track with
the financial plan developed in 2004 to support your revenue goal of $2 billion
within three years and if you were on track at the time you filed your 2004 10-K.

At the time the Company filed its 2004 Form 10-K, management had
obtained February’s financial results just days before.  While January and February sales
were disappointing, there were a number of large transactions in process during
mid-March, which, if closed, would have enabled the Company to achieve its
quarterly revenue milestone.  Due to the
seasonal nature of GTSI’s business driven by the buying patterns of the Federal
Government, historically January and February have been the Company’s
weakest months. Furthermore, it is difficult to draw conclusions on full year
sales based on the first two months of sales.

In mid-April, the Company finalized accounting for its first quarter
results.  Sales were significantly weaker
than projected under the Company’s CY 2005 Operating Budget.  Historically, first quarter sales have approximated
19% of GTSI’s annual sales (2001-2003).
During 2004, first quarter sales declined to 17% of the Company’s annual
sales.  Actual sales for the first
quarter of 2005 were approximately 11% of CY 2005 projected sales pursuant to
the Company’s Operating Budget. While the Company added approximately 150
additional sales people during the second half of CY 2004, these resources were
not as productive from a revenue generation perspective as previously
contemplated.

Based on actual financial results through May 2005, it appears
doubtful that the Company’s ambitious growth plan to double sales by 2007 will
be achievable within this time period without an acquisition. The Company has
revised its financial projections for the remainder of 2005, based on its year
to date results, comparisons of actual bookings to quotas, and shipping delays
due to difficulties with the implementation of the Company’s supply chain
management ERP system. These updated projections indicate the Company is not on
track at this time with the 2005 financial plan that was developed last year.
Therefore, the Company intends to announce in a press release that the Company’s
plan to double sales no longer seems achievable from a primarily organic
perspective within the three year timeframe previously projected. While GTSI
does not have any acquisition plans at this time, the Company is prepared to
pursue any accretive opportunities that arise. Such press release will be
included as an exhibit to a Form 8-K filed with the Commission. In addition,
the Company plans to update investors with its progress to date on GTSI’s
strategic financial plan in the Company’s Form 10-Q for the quarter ended June 30,
2005.

In conclusion, while the Company’s results are below projected
milestones at this time, management did not have any definitive information at
the time of filing its 2004 Form 10-K that sales milestones for the first
quarter and full year of 2005 would not be obtainable. The Company has very
little short-term visibility into sales patterns, which can vary significantly
from month to month.

Notes to Consolidated Financial Statements

Note 7.
Accounts Payable, p. 41

[FOIA Confidential Treatment pursuant to 17
C.F.R. §200.83 has been requested by GTSI in respect of its responses to
comments No. 3, 4 and 5.]

3

Prior Comment No. 5

6.                                      The
first part of our prior comment no. 5 regarding Selected Financial Data was
intended to refer to disclosures under Item 6 of your Form 10-K (page 17)
and not to your quarterly disclosures in Note 16 to your audited financial
statements.  Accordingly, we believe you
should revise Selected Financial Data to briefly describe and/or cross
reference to a discussion of the reversal of accounts payable (both the derecognition
of $10.1 million in aged accrued payables and the reversal of $2.5 million of
aged accrued payables) and the material effect that accounting had on the
comparability of the information presented.

In response to your comment 6, enclosed is the Form 10-K/A for
2004 GTSI intends to file with the Commission, which includes in Item 6,
Selected Financial Data the disclosure GTSI believes was requested by the
staff.  The Company has delayed filing
Amendment No. 2 to the 2004 Form 10-K to curtail the need to file
multiple amendments in order to respond to any further comments from the staff.

7.                                      We
continue to believe that you should expand the Overview section and/or
include a discussion of net income and operating income in MD&A to discuss
the significant impact the reversal of accounts payable (both the derecognition
of $10.1 million in aged accrued payables and the reversal of $2.5 million of
aged accrued payables) had on your operating income and net income.  In this regard, it appears that the annual and
quarterly trends in your operating income and net income would have been
materially different had you not derecognized/reversed these accounts payable
in the respective periods.  Similar
revisions in your discussion under the Gross Margin subheading of your MD&A
should also be made to discuss the reversal of $2.5 million of aged accrued
payables in addition to the derecognition of $10.1 million in aged accrued
payables.

The Company believes that the requested disclosures are set forth in
the enclosed proposed Form 10-K/A under the captions “Overview” and “Gross
Margin” in Item 7 Management’s Discussion and Analysis of Financial Condition
and Results of Operations.

If the Staff advises us that it has no further comments regarding the
2004 Form 10-K, GTSI will promptly thereafter file its Form 10-K/A
for 2004 with the Commission. While we believe that GTSI has fully responded to
the staff’s comments, if there are any further comments or questions regarding
this matter, we would respectfully request a meeting with the staff so that we
could resolve such further comments or questions.

  Sincerely,

  /s/ Thomas
  A. Mutryn

  Thomas A. Mutryn

  Senior Vice President and

             Chief
  Financial Officer

  Enclosure

4

DRAFT dated
June 30, 2005

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C.  20549

FORM 10–K/A

AMENDMENT No. 2

ANNUAL
REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT
OF 1934

For the fiscal year ended December 31, 2004

Commission File Number:
0–19394

GTSI CORP.

(Exact name of registrant as specified in its
charter)

  Delaware

  54–1248422

  (State or other
  jurisdiction of

  (I.R.S. Employer

  incorporation or
  organization)

  Identification No.)

  3901 Stonecroft Boulevard,
  Chantilly, VA

  20151-1010

  (Address of principal
  executive offices)

  (Zip Code)

  703–502–2000

  (Registrant’s telephone
  number, including area code)

Securities
registered pursuant to section 12(b) of the Act:  None

Securities
registered pursuant to section 12(g) of the Act:  Common Stock, par value
$0.005 per share

Indicate
by check mark whether the registrant (1) has filed all reports required to
be filed by Section 13 or 15(d) of the Securities Exchange Act of
1934 during the preceding 12 months (or for such shorter period that the
registrant was required to file such reports), and (2) has been subject to
such filing requirements for the past 90 days.          YES
ý
NO  o

Indicate
by check mark if disclosure of delinquent filers pursuant to Item 405 of
Regulation S-K is not contained herein, and will not be contained, to the best
of registrant’s knowledge, in definitive proxy or information statements
incorporated by reference in Part III of this Form 10-K or any
amendment to this Form 10-K.  o

Indicate
by check mark whether the registrant is an accelerated filer (as defined in Rule 12b-2
of the Act).          YES  ý         NO
o

The
aggregate market value of the voting common equity held by non-affiliates computed
by reference to the price at which the common equity was last sold, as of June 30,
2004 was $98,698,256.

The
number of shares outstanding of the registrant’s common stock on March 1,
2005 was 8,988,143.

1

DRAFT dated June 30, 2005

DOCUMENTS INCORPORATED BY REFERENCE

Items
10, 11, 12, 13 and 14 of Part III of this Form 10-K are incorporated
by reference to GTSI’s proxy statement filed with the Securities and Exchange
Commission on March 28, 2005 in connection with the Annual Meeting of
Stockholders held on April 21, 2005.

2

DRAFT dated June 30, 2005

EXPLANATORY NOTE

This
Amendment No. 2 to our Annual Report on Form 10-K for the year ended December 31,
2004 is being filed for the purpose of responding to comments received by us
from the Staff of the Securities and Exchange Commission. This Form 10-K/A
for 2004 includes these revisions and amends:

•                  Part II,
Item 6, Selected Financial Data. Added a cross reference to the discussion of
aged accrued payables and the effect on comparability between years presented
and

•                  Part II,
Item 7, MD&A. Expanded the Overview section and Gross margin
subheading of the 2004 Compared with 2003 section to discuss the affect of
the derecognition and reversal of aged accrued payables.

This
Amendment does not change any of the financial information previously reported
in the Company’s consolidated financial statements or any of the notes to such
consolidated financial statements.

This
Amendment speaks as of the original filing date of our Annual Report on Form 10-K
and has not been updated to reflect events occurring subsequent to the original
filing date of March 16, 2005. Accordingly, this amendment should be read
in conjunction with the Company’s filings with the SEC subsequent to the filing
of ou