SecProbe.io

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Mail Stop 0306

April 27, 2005

Via U.S. Mail and Facsimile (469) 892-1197

Julie Sansom-Reese
Chief Financial Officer
Zunicom, Inc.
1720 Hayden Road
Carrollton, Texas  75006

	Re:	Zunicom, Inc.
		Form 10-K for year ended December 31, 2004
		Filed March 31, 2005
		File No. 000-27210

Dear Ms. Sansom-Reese:

      We have reviewed your filings and have the following
comments.
We have limited our review to matters related to the issues raised
in
our comments.  Where indicated, we think you should revise your
future filings in response to these comments.  If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or a 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 comment or on any other
aspects
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the fiscal year ended December 31, 2004

Item 8 - Financial Statements and Supplementary Data

Report of Independent Registered Public Accounting Firm - Page F-3

1. Please have your auditor revise its report in future filings to
indicate the city and state where the opinion was issued.  Refer
to
Rule 2-02(a) of Regulation S-X.

Note B - Summary of Significant Accounting Policies

Revenue Recognition - Page F12

2. Your current disclosure on revenue recognition is vague.  We
note
that you offer various types of product, including batteries,
portable power products, security products and electronic
components.
We also note your reference on page 13 to "drop shipment sales."
We
also note that you provide power services, which includes
sourcing,
distribution, logistics and value added services.  It appears
these
power services agreements may be multiple element transactions.
Please supplementally respond to the following and revise future
filings to address our comments as appropriate:

a) Indicate your accounting policies for each type of material
sales
transaction, including power services.  In each instance,
demonstrate
how you satisfy each of the criteria for revenue recognition under
SAB Topic 13A.

b) Discuss any significant post-shipment obligations or any other
significant terms of your arrangements.  Tell us how these terms
impact your revenue recognition.  If you provide customers with a
product warranty, disclose how you account for that obligation
and,
if material, provide the roll-forward of the liability required by
paragraph 14 of FIN 45.

c) Discuss how you account for multiple-element arrangements.
Demonstrate how your policies comply with EITF 00-21 and SAB 104
by
identifying the separate units of accounting, disclosing how you
allocate the total consideration and disclosing how you determine
the
fair value of the undelivered elements.

* * * * * * * *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

	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.
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 in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; 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 filing or in
response to our comments on your filing.

      You may contact Praveen Kartholy, Staff Accountant, at (202)
824-5465, or me at (202) 824-5387 if you have questions regarding
these comments.  In this regard, do not hesitate to contact
Michele
Gohlke, Branch Chief, at (202) 942-7903.

					Sincerely,

					Kevin Vaughn
					Reviewing Accountant
Ms. Julie Sansom-Reese
Zunicom, Inc.
April 27, 2005
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