SecProbe.io

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<FILENAME>filename1.txt
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Mail Stop 0306

May 9, 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 response letter dated May 6, 2005 and
have the following additional comment.  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 our comment, we 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

Note B - Summary of Significant Accounting Policies

Revenue Recognition - Page F-12

1. We note your response to prior comment 2.  We see that your
drop
shipment sales are shipped directly from the third party vendor to
the customer.  It appears that you recognize revenue on a gross
basis
for these sales.  However, it appears that you do not take title
to
the inventory or make any modifications to the product.  Please
tell
us whether you recognize revenue on a gross or net basis for these
sales and quantify the amount of revenue recognized for each of
the
last three years.  If you have concluded that revenue should be
recognized on a gross basis for drop shipment sales, support your
conclusion with an analysis of the criteria discussed in EITF 99-
19.

* * * * * * * *

      As appropriate, please respond to this comment 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
response to our comment and provide 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 comment.

      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.
May 9, 2005
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