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[Mobility Electronics, Inc.]

November 14, 2005

Kathleen Collins

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Mobility Electronics, Inc.

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

    Filed March 11, 2005 (“Form 10-K”)

    File No. 000-30907

Dear Ms. Collins:

     On behalf of Mobility Electronics, Inc. (the “Company”), this letter is in
response to the comments contained in the Staff’s letter (the “Comment Letter”) dated
October 19, 2005, regarding the Company’s above-identified Form 10-K.

     The responses set forth below correspond to the numbers assigned in the Comment 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.

Response: SFAS No. 95, paragraph 26, note 10, states “Separate disclosure of cash
flows pertaining to extraordinary items or discontinued operations reflected in those categories
(Operating, Investing and Financing activities) is not required. An enterprise that nevertheless
chooses to report separately operating cash flows of discontinued

Kathleen Collins

November 14, 2005

Page 2 of 4

operations shall do so
consistently for all periods affected, which may include periods long after sale or liquidation of
the operation.” The Company supplementally advises the Staff that all cash flows from the
discontinued operation are operating in nature and that the Company has presented those cash flows
consistently for all periods presented.

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.

Kathleen Collins

November 14, 2005

Page 3 of 4

    (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.

Response: In response to Comments 2 and 3 above, the Company has restated its
previously issued financial statements for the three-month periods ended March 31, 2005 and June
30, 2005, the six-month period ended June 30, 2005, the years ended December 31, 2004 and 2003 and,
except for the first quarter of 2003, each of the quarters in 2003 and 2004, to record the fees and
expenses associated with the Company’s 2002 acquisitions of iGo Corporation and Portsmith that were
previously accounted for as a component of goodwill, as selling, general and administrative expense
in the appropriate period in which they were incurred (the “Restatement”).

     The Company, concurrent with the filing of this response letter, is filing amendments to its
Form 10-K for the year ended December 31, 2004, its Form 10-Q for the three months ended March 31,
2005, and its Form 10-Q for the three and six months ended June 30, 2005 (collectively, the
“Amended Filings”) to reflect this Restatement.

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

Kathleen Collins

November 14, 2005

Page 4 of 4

    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.

Response: In light of the Restatement, the Company supplementally advises the Staff that its management has
concluded that, as of December 31, 2004, March 31, 2005, June 30, 2005 and September 30, 2005, a
material weakness in the Company’s internal control over
financial reporting existed with respect to accounting
for costs incurred in connection with business combinations. As a result, this conclusion has been
reflected in the Amended Filings, as well as in the Company’s Quarterly Report on Form 10-Q for the
three and nine months ended September 30, 2005. The Company has subsequently designed and
implemented a new procedure as part of its internal controls over financial reporting that requires
additional management approval for all costs affecting goodwill, and adds an additional
level of management review to evaluate on a quarterly basis the accounting treatment of costs
associated with business combinations to determine that such treatment is consistent with the
guidance of SFAS No. 141, “Business Combinations.”

     Please contact me at (480) 477-3636 to discuss any questions you may have.

    Sincerely,

    MOBILITY ELECTRONICS, INC.

    /s/ Joan W. Brubacher

    Joan W. Brubacher

    Executive Vice President & CFO

    cc:

    April Coleman, Staff Accountant

    Lisa Mitrovich, Assistant Chief Accountant

    Brian Roberts, General Counsel, Mobility Electronics, Inc.

    Richard F. Dahlson, Jackson Walker, LLP