SecProbe.io

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Mail Stop 0306

May 13, 2005

Via U.S. Mail and via Facsimile

Mr. Ronald E. Badke
Chief Financial Officer
1840 County Line Road
Huntingdon Valley, PA 19006

	RE:	Wireless Xcessories Group, Inc.
		Form 10-KSB for the year ended December 31, 2004
		Form 10-QSB for the quarter ended March 31, 2005
		File No. 0-27996

Dear Mr. Badke:

     We have reviewed your response letter dated April 30, 2005
and
have the following additional comments.  We have limited our
review
to those issues we have addressed in our comments.  Where
indicated,
we think you should revise your filings in response to these
comments.  If you disagree, we will consider your explanation as
to
why our comments are 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
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 year ended December 31, 2004

Consolidated Financial Statements

Note 1 - Revenue Recognition - Page F-10

1. Your response to our prior comment 5 indicates that you provide
value added services when a customer wants to offer a full product
line to their end users.  In doing so, you provide email programs,
charts, and training materials.  Specifically address the
following:
a) Tell us how you package these items and if you have considered
these as separate units of accounting under the EITF 00-21.
b) Tell us when each of these items is delivered and if you
separately recognize revenue for each deliverable.
c) Describe to us the email programs and e-commerce websites you
offer and explain how you considered SOP 97-2 in establishing your
revenue recognition policy.
2. Your response to our prior comment 5 indicates that you provide
in-store displays and posters to your customers who order in high
volume.  Tell us how you account for these incentives.  Explain
how
you considered EITF 01-09 in establishing your  accounting.
3. Your response to prior comment 5 confirms that you provide a
warranty to your customers that your products are free of defects
for
up to 60 days after sale.
a) Tell us and revise future filings to disclose how you account
for
the warranty, including the methodology you use to establish the
amount of the liability.
b) If material, in future filings disclose a roll-forward of the
warranty liability as required by paragraph 14 of FIN 45.

Item 14, Controls and Procedures - Page 19

4. We note your response to our prior comment 7.  Please note that
the correct references to the definition of disclosure controls
and
procedures are found in the Exchange Act, Rules 13a-15(e) and 15d-
15(e).
5. It does not appear that your certifying officers have concluded
that your disclosure controls and procedures are effective, given
the
statement in your proposed disclosure that that your disclosure
controls and procedures are effective only with regard to timely
alerting management of reports filed.  Please note that the
definition of disclosure controls and procedures found in the
Exchange Act, Rules 13a-15(e) and 15d-15(e), includes the
following
two parts.
i. Controls and other procedures that are designed to ensure that
information required to be disclosed by the issuer in reports that
it
files or submits under the ACT is recorded, processed, summarized
and
reported, within the time periods specified in the Commissions`
rules
and forms, and
ii. Controls and procedures designed to ensure that information
required to be disclosed by an issuer in the reports that it files
or
submits under the ACT is accumulated and communicated to the
issuer`s
management, including its principal executive and principal
financial
officers, or persons performing similar functions, as appropriate
to
allow timely decisions regarding required disclosure.
If you wish to include the definition following your conclusion,
please ensure it is consistent with the definition included in
Rule
13a-15(e) of the Exchange Act.
6. We note your response to our prior comments 8 and 10.  Please
include the proposed disclosure related to these issues in prior
comments 7 and 9 in your amended 10-KSB.
7. Please refer to your response to our prior comment 9.  We note
your statement that "there were no changes in the Company`s
internal
control over financial reporting that have come to managements
attention during the company`s fourth quarter of 2004..."
Consistent
with the language used in Item 308(c) of Regulation S-B, as
amended,
please revise the language used in your disclosure concerning
changes
in your internal control over financial reporting to indicate
whether
there was any change to your internal control over financial
reporting that has materially affected, or that is reasonably
likely
to materially affect, your internal control over financial
reporting,.
8. Please confirm that you will file the correct form of
certifications in your amended 10-KSB.

Form 10-Q for the quarter ended March 31, 2005

9. In future filings, to eliminate investor confusion, revise to
correctly identify and label the items of Form 10-QSB.

*    *    *    *

      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 responses to our
comments.

      You may contact Heather Tress, Staff Accountant, at (202)
824-
5263 or me at (202) 942-1984 if you have questions regarding
comments
on the financial statements and related matters.

							Sincerely,

							Martin F. James
							Senior Assistant Chief
Accountant
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Mr. Ronald E. Badke
Chief Financial Officer
Wireless Xcessories Group, Inc.
May 13, 2005
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