SecProbe.io

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Mail Stop 4561

      							August 30, 2005

Mr. Robert J. Crowell
Chief Executive Officer
Elcom International, Inc.
10 Oceana Way
Norwood, Massachusetts 02062

	Re:	Elcom International, Inc.
		Form 10-KSB for the Fiscal Year Ended December 31, 2004
		Form 10-QSB for the Fiscal Quarter Ended March 31, 2005
		Form 10-QSB for the Fiscal Quarter Ended June 30, 2005
      File No. 000-27376

Dear Mr. Crowell:

		We have reviewed the above referenced filings and have
the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  We may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  After reviewing this information, we may 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
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Note (2) Summary of Significant Accounting Policies

(h) Revenue Recognition, page F-9

1. We note that your revenue consists principally of
implementation,
consulting and training fees for new licenses and ongoing fees for
hosting, licensing and maintenance of software.  Your disclosure
further indicates that you recognize revenue using the residual
method in accordance with SOP 98-9.  Clarify the arrangements for
which you apply the residual method and how you have evaluated the
appropriateness of applying the residual method to these
arrangements
pursuant to paragraph 5 of SOP 98-9.  As part of your response,
identify the delivered and undelivered elements in your
arrangements
and identify the elements where you believe you have established
vendor-specific objective evidence (VSOE) of fair value and those
that you have not.  For elements where VSOE of fair value exists,
explain and justify the manner in which VSOE was established.
Refer
to paragraph 10 of SOP 97-2.

2. Your disclosure on page 14 indicates that you have established
VSOE of fair value of maintenance based on renewal rates.  Explain
how you have considered the guidance in AICPA Technical Practice
Aid,
Section 5100.53 and 54 when establishing fair value of maintenance
in
short-term time-based licenses and long-term time based licenses,
respectively.

3. We note that professional services, including implementation
and
training, are generally recognized at the time the services are
performed, which appear to precede the license, hosting and
maintenance period.  Clarify how you recognize revenue for these
professional services in arrangements that contain elements for
term
license, hosting and maintenance services.  Tell us how you
consider
the guidance of paragraphs 12, 66 and 67 of SOP 97-2 when
determining
the appropriate timing to recognize your professional service
revenue.

4. We note that you offer a hosted version of your software
license
and that your treatment of revenue generated from your hosting
services has historically been consistent with EITF 00-3.  Explain
whether the application of EITF 00-3 to your hosting arrangements
requires you to recognize hosting revenue pursuant to SOP 97-2 or
SAB
Topic 13.  Specifically tell us whether or not your customers have
the contractual right to take possession of the software at any
time
during the hosting period without significant penalty and it is
feasible for the customer to run the software on its own.
Further,
tell us where you classify your revenues from hosting services in
your Statements of Consolidated Income.  In your response provide
your hosting revenues recognized for all periods presented.

5. We note from your disclosure on page 10 and F-16 that you
recognized the fourth and final lump sum license payment from
Capgemini UK Plc of $1,142,000 as revenue, which was earned upon
signing the thirteenth customer of the eProcurement Scotland
program
in the first quarter 2004.  Provide us a summary of your agreement
with Capgemini, including a summary of the scope of work, total
contract value, contract period, elements of the arrangement and
acceptance provisions.  Further, clarify the revenue recognition
literature that you applied to this agreement and why you
considered
it appropriate to recognize as revenue the fourth payment in this
arrangement upon signing the thirteenth customer to this program.
Tell us whether you were required to provide any additional
services
or had any additional obligations to Capgemini or the end customer
after recognizing this revenue.  Tell us when you recognized
revenue
for the first three license payments in this arrangement and how
you
determined that revenue was earned.  Further, clarify how your
revenue recognition disclosure addresses your policy for
recognizing
revenue in this arrangement.  Separately address your revenue
recognition policies for the implementation fees, monthly hosting
and
maintenance fees you receive for each entity that joins the
eProcurement Scotland Program.

6. Tell us how you will account for the Revenue Sharing Agreement
you
entered into on August 12, 2005.  Provide us a summary of the
general
terms of the Agreement and refer to the authoritative accounting
literature that supports your intended accounting.

Note (6) Stockholders` Equity

(f) Convertible Debentures, page F-19

7. We note that you amended your convertible debenture agreements
in
fiscal year 2004 to provide that interest is payable in-kind (PIK)
upon conversion or maturity.  Tell us how you consider EITF 00-27,
Issue 10 when determining the commitment date for the convertible
instruments that are issued as PIK interest.  Clarify whether the
measurement date represents the date of the original convertible
instrument to which the PIK issuance related, the date of the
modified agreement or the date the interest is recognized as a
liability and the basis for your conclusion.  Further, clarify how
you are accounting for interest as accrued and whether your
accounting results in a beneficial conversion discount.

*****

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please submit
all
correspondence on EDGAR as required by Rule 101 of Regulation S-T.
Please understand that we may have additional comments after
reviewing your response to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 filing;

* staff comments or changes to disclosure in response to staff
comments 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 Christopher White, Staff Accountant, at (202)
551-3461, Lisa Mitrovich, Assistant Chief Accountant at (202) 551-
3453 or me at (202) 551-3730 if you have any questions regarding
our
comments on the financial statements and related matters.

								Sincerely,

								Stephen Krikorian
								Accounting Branch Chief

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Mr. Robert J. Crowell
Elcom International, Inc.
August 30, 2005
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