SecProbe.io

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May 6, 2005

Mr. Kevin Vaughn
Reviewing Accountant
Mr. Praveen Kartholy
Staff Accountant
United States Securities and Exchange Commission
Division of Corporate Finance
Washington, DC 20549

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

Dear Mr. Vaughn and Mr. Kartholy,

         We have received your comment  letter of April 27, 2005 and  appreciate
an  opportunity  to clarify the recent  filing of our Annual Report on Form 10-K
for the year ended  December 31, 2004.  We  understand  that the purpose of your
review is to assist us in compliance with the applicable disclosure requirements
and to  further  assist  us  with  the  overall  disclosure  in our  filing.  We
acknowledge that the Company is responsible for the adequacy and accuracy of the
disclosure in the filings.  We acknowledge that the 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 filings.
Furthermore,  we acknowledge that 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.

         As an aid to  understanding  the Company's  responses to staff comments
each comment is listed below with the Company's response  immediately  following
the applicable comment.

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

Staff Comment:
-------------
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.

Company Response:
----------------

Noted and will provide requested information in all future filings.

                                       1

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Staff Comment:
-------------
Note B - Summary of Significant Accounting Policies
---------------------------------------------------
Revenue Recognition - Page F-12
-------------------------------

     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 flings 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.

Company Response:

2 a)
----
         The Company has two segments: the battery and fulfillment sales segment
which  represents  the  operations  of Universal  and the facsimile and business
center  segment  which  represents  the  operations  of  AlphaNet.  Universal is
essentially  an importer  and  distributor  of  batteries  and  battery  related
products. AlphaNet provides computer related access services to hotels.

         Universal  is a  distributor  who  purchases  both  finished  goods and
components  from domestic and  international  suppliers.  Universal's  customers
order finished goods,  either bulk battery product or single shippable units, to
fill their  requirements.  The Company adds value to products and  components by
packaging  them in  customer  specified  "kits" or tailor  made  units  that are
convenient  for the  customer to order and ship.  As an example,  Universal  may
purchase, in bulk quantities,  batteries,  wiring harnesses,  control panels and
similar items necessary to install a residential  security system. Each security

                                       2

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system  installation  may require only one or two of the items purchased in bulk
by the  Company.  As a  value  added  service  Universal  will  pick  the  small
quantities of components  from the bulk supply and repackage  them into a single
shippable  unit for the  convenience  of  Universal's  customer.  Universal then
markets  and sells the  single  shippable  unit as a  complete  product to their
customer. This arrangement is available to many of Universal's customers but the
single  largest  customer is Brinks Home  Security.  The Company  refers to this
service  as  "Third  Party  Logistics".   Additionally,  Universal  has  several
customers  that require  specific  battery  solutions for inclusion in their own
products.  Universal  will  obtain the  battery  and  necessary  components  and
configure  a new  finished  good unit based upon  customer  specifications.  The
Company refers to this process as a "value added service". Generally,  Universal
recognizes sales of finished goods upon the shipment of the product.

         Universal  sells  products  to several  customers  in  quantities  that
represent a full  container  load of product  obtained from pacific rim sources.
Universal  obtains the order from the  customer and arranges for the shipment of
product  directly from  Universal's  vendor to reduce freight costs and wear and
tear on the  product  from  excessive  handling.  Because the product is shipped
directly from Universal's  vendor to Universal's  customer the Company refers to
these sales as "drop shipments".  Generally, Universal recognizes revenue at the
time the customer takes title to the product.

         Universal does not enter into service contracts with customers.

Universal satisfies the four criteria for determining that revenue is realizable
as defined under SAB Topic 13A as follows:

   o  Persuasive evidence of an arrangement exists

   The Company receives purchase orders or other written  information from their
   customers.  These  purchase  orders  indicate  the item,  price and  quantity
   desired, as well as the desired shipping and billing terms.

   o  Delivery has occurred or services have been rendered

   The Company  ships its finished  goods by common  carrier,  by United  Parcel
   Service  or by  other  commercial  means.  The  merchandise  that is  shipped
   directly  from the overseas  vendor to the customer is shipped on  commercial
   shipping  lines.  Delivery is  considered  complete at the time the  customer
   takes title to the product as shipping terms vary.

   o  The seller's price to the buyer is fixed or determinable

   The price is quoted to the customer  either by phone,  by catalog or by other
   means. The customer  indicates their agreement to the price of the product by
   placing their order.  Standardized  price lists are used with some  customers
   while many of the large volume  customers have annual  pricing  programs that
   are offered in advance.

   o  Collectibility is reasonably assured.

   The Company  offers open  credit to many of its  customers,  bills each order
   upon transfer of title,  and has a very low experience rate of  uncollectible

                                       3

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   accounts  and  almost  no  examples  of  customers  asserting  a claim of not
   receiving  the goods or not  ordering  the  goods.  The most  common  type of
   uncollectible  account is bankruptcy or other type of liquidation on the part
   of the customer.  The Company  considers  these as well as other factors when
   determining the allowance for doubtful accounts.

         AlphaNet provides computer related access services to hotels.  AlphaNet
places  computer  components  in the hotel  properties  which allow hotel guests
access to facsimile  machines,  computers and other office equipment.  The hotel
guests  use the  equipment  on a fee per minute  basis  which  AlphaNet  tracks.
AlphaNet bills either the hotel property or the customer  directly at the end of
each fee per minute session.  Much of this business is conducted  through credit
cards.  AlphaNet  records  the sale upon  completion  of the  session.  AlphaNet
represents less than 3% of the Company's overall sales volume.

2 b)
----
         Universal  offers its customers a limited  warranty for  replacement of
finished goods that do not function properly for approximately one year. Certain
battery  chemistries  require a slightly  shorter  warranty  period  while other
chemistries have an extended  warranty period.  The vast majority of Universal's
product  offerings  have a one year limited  warranty.  The most common types of
warranty complaints are batteries that leak or batteries that do not provide the
voltage they are intended to supply.  The Company's  written warranty is limited
to the  replacement of the product  purchased and does not cover the product the
battery is used in. The Company's  replacement rate is insignificant,  less than
0.25% of total sales, and is therefore recorded as a reduction of sales when the
warranty  expensed is  incurred.  If the Company  determines  that a shipment of
product  has  a  manufacturing   defect,  the  Company  has  recourse  with  the
manufacturer to recover the replacement  costs incurred but the cost of isolated
or individual instances of defects are borne by the Company.

         Universal has no other post-shipment obligations.  The Company does not
offer any type of post-sale servicing.

         AlphaNet  does not sell  products and as such warranty or post shipment
obligations are not applicable.

2 c)
----
         Universal  does not  enter  into  revenue  arrangements  with  multiple
deliverables as defined in EITF 00-21 AND SAB 104.

         The Company  proposes the following  expanded  disclosure in all future
filings of its revenue recognition and post shipment obligations.

Revenue Recognition

         The  Company  recognizes  revenue  in  accordance  with  SAB  104  when
persuasive evidence of an arrangement exists,  delivery has occurred,  the price
is fixed and  determinable  and  collectiblity  is reasonably  assured.  Revenue
recognition for specific types of revenue are described below.

         Universal  is a  distributor  who  purchases  both  finished  goods and
components  from domestic and  international  suppliers.  Universal's  customers

                                       4

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order finished goods,  either bulk battery product or single shippable units, to
fill their requirements

         The Company adds value to products and  components by packaging them in
customer  specified  "kits" or tailor  made  units that are  convenient  for the
customer to order and ship.  Additionally,  Universal has several customers that
require  specific  battery  solutions  for  inclusion  in  their  own  products.
Universal  will obtain the battery and necessary  components and configure a new
finished good unit based upon  customer  specifications.  The Company  refers to
this process as a "value added service".  Generally,  Universal recognizes sales
of finished goods at the time the customer takes title to the product.

         Universal  sells  products  to several  customers  in bulk  quantities.
Universal  obtains the order from the  customer and arranges for the delivery of
the product directly from  Universal's  vendor to the customer to reduce freight
costs and wear and tear on the product from excessive handling. Universal refers
to these  transactions  as "drop  shipments"  because  the  product  is  shipped
directly from Universal's vendor to Universal's customer.  Generally,  Universal
recognizes revenue at the time the customer takes title to the product.

         AlphaNet provides computer related access services to hotels.  AlphaNet
places  computer  components  in the hotel  properties  which allow hotel guests
access to facsimile  machines,  computers and other office machinery.  The hotel
guests  use the  equipment  on a fee per minute  basis  which  AlphaNet  tracks.
AlphaNet bills either the hotel property or the customer  directly at the end of
each fee per minute session.  Much of this business is conducted  through credit
cards. Generally, AlphaNet records the sale upon completion of the session.

Post Shipment Obligations:

         Universal  offers its customers a limited  warranty for  replacement of
finished  goods that do not function  properly.  Generally the limited  warranty
period is for one year.  The most common types of warranty  claims are batteries
that leak or  batteries  that do not provide the  voltage  they are  intended to
supply.  The  Company's  warranty is limited to the  replacement  of the product
purchased  and does not cover the product  the battery is intended to power.  At
December  31,  2004,  2003,  and 2002 the  Company  has a  warranty  reserve  of
approximately  $10,000.  Warranty  expenses are recorded as a reduction of sales
when credit is issued.

         The Company  believes that it has complied with the Staff's comments as
requested.

         Please call me at (469)  892-1200  with any comments or questions  that
you may have with respect to the enclosed filing, or if we may be of any further
assistance.

Sincerely,

/s/ Julie Sansom-Reese
-----------------------
Julie Sansom-Reese
Chief Financial Officer

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