SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

May 23, 2005

Mr. Kevin Vaughn                      Via U.S. Mail and Facsimile (202) 942-9585
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 May 9, 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 and our letter of May 6, 2005.  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.

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

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

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

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.

                                       1

<PAGE>

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

       In reviewing the criteria for revenue  recognition on drop shipment sales
       as detailed in EITF 99-19 the Company notes the following:

       1)   EITF 99-19 "Reporting  Revenue Gross as a Principal versus Net as an
            Agent" is applicable in  determining  sales revenue on drop shipment
            sales for the Company.

       2)   The  Company,  after  analyzing  the  requirements  of  EITF  99-19,
            believes it meets the requirements for reporting  revenue on a gross
            basis. Specifically,

            a)   The Company,  in  conjunction  with its  customer,  designs the
                 product, establishes product and packaging parameters, requests
                 and   tests   product   samples   before   ordering,   requests
                 modification  of the  product to  optimize  quality  and price,
                 negotiates  price and  selects  the vendor that will be used to
                 produce the product. The Company handles all communication with
                 its vendor and arranges customer's delivery. The Company is the
                 primary obligor in the arrangement.

            b)   The Company has latitude in establishing  the price of products
                 being sold to its customers  within  economic  constraints.  In
                 addition to price the Company determines whether agents will be
                 used to expedite  the order to ensure the Company  receives the
                 product at the best  price from the vendor and of a  consistent
                 quality.  The use of an  agent is  solely  at the  expense  and
                 desire of the Company and does not affect the customer pricing.

            c)   The Company has discretion in supplier  selection.  The Company
                 has multiple  suppliers  for a product or service  ordered by a
                 customer and uses  discretion  in selecting  the supplier  that
                 will provide the product as long as the quality  parameters are
                 met.

            d)   The  Company  is  involved  in the  determination  of  products
                 specifications.  Generally  the  Company  offers a  variety  of
                 battery  products to its customer from which the customer makes
                 their  selection.   Often  the  customer  will  request  unique
                 features  or  enhancements  to an  existing  product or product
                 packaging  to  ensure  a  competitive  advantage.   It  is  the
                 Company's  responsibility  to create and document the requested
                 changes,  communicate the  information to the selected  vendor,
                 test the  modified  product for  performance,  perform  quality
                 control  testing,  and  submit  the  modified  product  to  the
                 customer for final review. In almost every instance the Company
                 possesses greater experience and skill in understanding battery
                 design and modification than the customer,  who is most often a
                 retailer or  wholesaler  of a multiple  line of  products  with
                 generalized expertise.

                                       2

<PAGE>

            e)   The Company has credit  risk.  The Company  contracts  with the
                 supplier  for the  production  of the  goods.  If the  customer
                 canceled  its purchase  order after  production  commenced  the
                 Company's  obligation  to the supplier  remains  intact and the
                 Company  would  either  find a  substitute  purchaser  or  take
                 possession  of  the  finished   goods  in  its  own  inventory.
                 Additionally the Company offers  commercial credit terms to its
                 customers  allowing for payment of the product a number of days
                 after receipt, generally sixty days from receipt of goods.

       3)   There are two indicators of Gross Revenue Reporting that the Company
            does not meet,  however the Company  believes they are outweighed by
            the indicators listed above. Specifically,

            a)   The Company  does not have  general  inventory  risk before the
                 order is  placed  but does  have  general  inventory  risk upon
                 customer  return.  If the product is found to be defective  the
                 Company has  recourse  with the supplier but if the product was
                 produced to the agreed upon  specifications,  but the  customer
                 refused  to pay for  the  product,  the  Company  would  suffer
                 general  inventory  risk and would be  forced  to  either  take
                 possession of the product or resell it to another customer.

            b)   The Company  does not change the product or perform  service on
                 the product once it is produced.

         The Company notes in EITF 99-19 that whether a company should recognize
         revenue based on (a) the gross amount  billed to a customer  because it
         has earned  revenue  from the sale of the goods or  services or (b) the
         net amount  retained  (that is, the amount  billed to the customer less
         the amount paid to a supplier)  because it has earned a  commission  or
         fee is a matter of  judgment  that  depends on the  relevant  facts and
         circumstances and that the factors or indicators listed above should be
         considered  in that  evaluation.  The  Company  believes  it meets  the
         criteria for Gross revenue  recognition because the indicators of Gross
         Revenue Reporting the Company meets outweigh the indicators the Company
         does not meet.

         The total value of direct  shipments for the years ending  December 31,
         2004,  2003  and  2002  are  $4,445,000,   $7,843,000  and  $6,200,000,
         respectively or approximately 6%, 13% and 13% of consolidated revenue.

         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
                                       3

</TEXT>
</DOCUMENT>