SecProbe.io

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Room 4561

      October 19, 2005

Mr. Charles R. Mollo
President and Chief Executive Officer
Mobility Electronics, Inc.
17800 N. Perimeter Drive
Suite 200
Scottsdale, AZ  85255

Re:	Mobility Electronics, Inc.
	Form 10-K for Fiscal Year Ended December 31, 2004
	Filed March 11, 2005
	File No. 000-30907

Dear Mr. Mollo:

      We have reviewed your response to our letter dated July 26,
2005 in connection with our review of the above referenced filings
and have the following comments.  Where indicated, we think you
should revise your document in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
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
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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

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

Statement of Cash Flows, page 42

1. Tell us how your presentation of cash flows used in
discontinued
operations is consistent with the guidance in SFAS No. 95,
specifically paragraphs 26, 28 and 29.  In this regard, if the
cash
flows relating to discontinued operations are separately
presented,
separate disclosure of such cash flows should be made within all
three categories of cash flows (i.e., operating, investing and
financing, when applicable).  Please advise, and revise as
necessary.

Note 6  Goodwill, page 51

2. We have reviewed your response to our Prior Comment No. 4,
regarding the allocation period for the iGo acquisition and have
the
following additional comments:

a. Tell us how you accounted for this pre-acquisition contingency
when you performed the initial purchase price allocation
associated
with the September 3, 2002 acquisition of iGo.  Quantify the fair
value of this contingency at the initial purchase price allocation
and how you determined that amount.  Your response should describe
the nature of the evaluation that was performed, when the
evaluation
was complete and the estimated range of loss that was determined
as a
result of the evaluation.

b. Your response provides a quote from SFAS No. 141 which
indicates
"The allocation period ends when the acquiring entity is no longer
waiting for information that it has arranged to obtain and that is
known to be available or obtainable."  This suggests that you
were/are waiting for information that you arranged to obtain.  If
so,
specifically identify the additional information you arranged to
obtain and when that information became available.  Refer to
paragraph B183 of SFAS No.141.

c. While SFAS No. 141 does indicate the allocation period should
usually not exceed one year, explain the basis under generally
accepted accounting principles to hold the allocation period open
until the investigation/litigation is resolved.  In this regard,
it
appears that you believe the allocation period is still open in
light
of the fact that you have continued to record legal costs as an
increase to goodwill during the interim period ended March 31,
2005.
Please explain to us why you believe it is appropriate to extend
the
allocation period more than two years from the date of
acquisition.
Refer to paragraph B183 of SFAS No. 141 and SAB Topic 2.A.7.

d. Your response further suggests that the SEC investigation of
the
former directors and officers of iGo Corporation is an "unusual
pre-
acquisition contingency" which appears to be the basis for you to
extend the allocation period beyond one year.  Please tell us why
you
believe the nature of the pre-acquisition contingency (i.e., usual
versus unusual) would allow you to extend the allocation period
beyond one year.  Also, further demonstrate why you believe this
investigation is `unusual` in light of the number of pending SEC
investigations.

e. Also, tell us how you consider the disclosure guidance in SAB
Topic 2.A.7.  In this regard, explain why you did not provide
disclosure that the purchase price allocation was preliminary,
along
with the nature of the contingency and other available information
that would enable a reader to understand its potential effects on
the
final allocation and on post acquisition results.

f. Also, tell us how your accounting for this contingency and
respective insurance recovery follows the guidance in SFAS No. 5
and
FIN 39.  In this regard, your disclosure on page 61 indicates that
you are pursuing coverage under iGo`s directors` and officers`
liability insurance policy regarding potential indemnification
claims; however, if coverage is not received, you may be
responsible
for costs and expenses associated with this matter.  Tell us how
you
have evaluated this liability and the related insurance recovery
with
reference to the respective authoritative literature.
3. We have reviewed your response to our Prior Comment No. 4
regarding your dispute with Portsmith over contingent
consideration;
however, we do not believe you have provided persuasive evidence
or
analysis to support your conclusion that the fees incurred in
connection with the resolution of the consideration represent a
direct acquisition cost and result in an increase to goodwill.  We
believe that adjustments and /or payments that arise out of
litigation over the purchase price between the acquirer and the
former owners of the acquired company should be charged to income
when settled.  Refer to paragraph B177 of SFAS No. 141.

Item 9A Controls and Procedures, page 63

4. Please confirm supplementally, if true, that as of December 31,
2004 and March 31, 2005, your disclosure controls and procedures
were
`effective` to ensure that information required to be disclosed by
you in the reports that you file or submit under the Exchange Act
is
recorded, processed, summarized and reported, within the time
periods
specified in the Commission`s rules and forms and to ensure that
information required to be disclosed by an issuer in the reports
that
it files or submits under the Exchange Act is accumulated and
communicated to your management, including its principal executive
and principal financial officers, or persons performing similar
functions, as appropriate to allow timely decisions  regarding
required disclosure.

* * * * *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      You may contact April Coleman, Staff Accountant, at (202)
551-
3458 or Lisa Mitrovich, Assistant Chief Accountant, at (202) 551-
3453
or me at (202) 551-3730 if you have questions regarding comments
on
the financial statements and related matters.

							Sincerely,

							Kathleen Collins
							Accounting Branch Chief
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Mr. Charles R. Mollo
Mobility Electronics, Inc.
October 19, 2005
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