SecProbe.io

Mail Stop 3561
May 2 , 2017

Timothy McGrath
President and Chief Executive Officer
PC Connection,  Inc.
730 Milford Road
Merrimack, New Hampshire  03054

Re: PC Connection, Inc.
 Form 10-K for Fiscal Year Ended December 31,  2016
Filed March 3, 2017
File No. 0-23827

Dear Mr. McGrath :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstanc es, please  tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 21

Year -Over -Year Comparis ons

Year Ended December 31, 2016 Compared to Year Ended December 31, 2015, page 24

1. We note that you identify more than one factor underlying increases in net sales related to
your SMB and Large Account segments  and selling, general and administrative exp enses
without quantifying the impact of the factors.   In future filings please quantify , to the
extent practical , the impact of each factor identified.   Refer to Item 303(a)(3) of
Regulation S -K and SEC Release No.  34-48960.

Timothy McGrath
PC Connection, Inc.
May 2, 2017
Page 2

 Signatures, page 44

2. The re port must be signed on behalf of the registrant by its principal executive officer, its
principal financial officer, its controller or principal accounting officer and by at least a
majority of the board of directors .  Any person who occupies more than one  of the
specified positions must indicate each capacity in which he signs the report.  We note the
report was not signed by your controller or principal accounting officer in the second
signature block.  Please revise.  Refer to the signature page in Form 10-K and General
Instruction D(2) of  Form 10 -K.

Item 8.  Consolidated Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements

6. Bank Borrowings, page F -16

3. We note your disclosure that your credit facility and trade credit agreements contain
certain financial ratios and operational covenants and other restrictions .  Please clarify
your disclosure and tell us whether the other restrictions pertain to the payment of
dividends.  If so, please tell us your consideration o f disclos ing the amount of retained
earnings or net income restricted or free of restriction in accordance with Rule 4 -08(e)(1)
of Regulation S -X.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their d isclosures, notwithstanding any review, comments, action or a bsence of
action by the staff.

You may contact Yolanda Guobadia, Staff Accountant  at (202) 551 -3562 , Donna Di
Silvio, Staff Accountant at (202) 551 -3202  or me at (202) 551 -3344 if you have que stions
regarding our comment s or any other questions.

Sincerely,

 /s/ William H. Thompson

 William  H. Thompson
Accounting Branch Chief
Office of Consumer Products