SecProbe.io

September 29, 2025
Thomas C. Baker
Chief Financial Officer
PC Connection, Inc.
730 Milford Road
Merrimack , New Hampshire 03054
Re:PC Connection, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2024
Form 10-Q for the Fiscal Period Ended June 30, 2025
File No. 000-23827
Dear Thomas C. Baker:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-Q for the Fiscal Period Ended June 30, 2025
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Summary of Sources and Uses of Cash, page 26
1.Your disclosure appears to discuss how reported operating cash was derived for each
period, as already presented in the statement of cash flows. Rather, your disclosure
should be a comparative analysis of the change from period to period in the reported
amount of operating cash flows. Refer to Item 303(b) and (c) of Regulation S-K.
Please revise as appropriate.

September 29, 2025
Page 2
Form 10-K for the Fiscal Year Ended December 31, 2024
Item 2. Properties, page 27
2.You disclose the two Merrimack leases with a related party have expired and you
continue to occupy the facilities. You state you continue to pay rent and other
associated costs for these facilities. Please tell us whether you continue to record these
facilities as leases in your financial statements and disclose your intention to enter into
new leases for them. Also, tell us where cash paid for these facilities is reported,
similar to amounts reported in note 7 for cash paid in the measurement of lease
liabilities and capitalized leases. Further, tell us whether amounts for these facilities
are reflected in the schedule of future lease payments and the ROU asset/lease liability
balances in note 7.
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Year-Over-Year Comparisons
Year Ended December 31, 2024 Compared to Year Ended December 31, 2023
Gross profit, page 34
3.You discuss increases in gross profit and/or gross margin in terms of the amount of
software sales recognized on a net basis and/or improved invoice margins. Please
explain to us and disclose why and how software sales recognized on a net basis
positively impact gross profit and gross margin and the basis for improved invoice
margins. Compare and contrast your reference here to product sales to your
disclosures on pages 30 and 31 that service offerings carry higher margins than
traditional product sales and service revenues have higher margins but neither is
identified here as contributing to improved gross profit/margins. Also, we note cost of
sales appears to be material to your results of operations. In this regard, for each
segment, discuss and quantify the extent changes in cost of sales impact gross profit
and gross margin. In your revised disclosure, discuss and quantify the significant
components of costs of sales, to the extent material. Refer to Item 303(b) and (2)(i)
and (2)(iii) (relative to improved invoice margins, if applicable) therein.

September 29, 2025
Page 3
Consolidated Statements of Income, page F-5
4.Please explain to us why you do not separately present revenue from services and cost
of services pursuant to Rule 5-03(b)1(d) and 2(d) of Regulation S-X.
            In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
            Please contact Aamira Chaudhry at 202-551-3389 or Doug Jones at 202-551-3309
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services