SecProbe.io

April 24, 2013

Via E -mail
Ms. Kathleen M. Griggs
Chief Financial  Officer
j2 GLOBAL, INC.
6922 Hollywood Boulevard, Suite 500
Los Angeles, CA 90028

Re: j2 GLOBAL, INC.
Form 10-K for the Year Ended December 31 , 2012
Filed March 1, 2013
File No. 0-25965

Dear Ms. Griggs :

 We have reviewed your filing and have the following comments.  Please comply with the
following comments in future filings.  Confirm in writing that you will do so and explain to us
how you intend to comply.   In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
inform ation  or by advising us when you will provide the requested response.   If you do not
believe our comment s apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these commen ts, we may
have  additional comments.

Form 10 -K for the  Year Ended December 31 , 201 2

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Results of Operations, pages 35 -39

1. Please quantify the amount and per centage of the period -to-period changes attributable to
foreign exchange rates.  We note your disclosure on page 43 that the changes in foreign
currency exchange rates impact your results of operations.  Refer to FRC 501.09(b).

2. We note that the pricing of  your services has an impact on your revenues.  Please
separately discuss the impact of price and volume on your revenues and results of
operations.

Ms. Kathleen M. Griggs
j2 GLOBAL, INC.
April 24, 2013
Page 2

 3. Please d iscuss whether you expect the reported trends to continue or change and the
reasons why.

4. We note  your cancel rates discussion in your Form 8 -K filed February 14, 2013 and your
earnings call.  Please provide such discussion in the MD&A or tell us why such
discussion is not necessary.  We also note your discussion of cancellations in your risk
factors section.

5. We note your ARPU disclosures in your earnings call.  Please provide  such disclosures in
the filing including the usefulness of ARPU to investors or tell us why such disclosures
are not necessary.

3. Business Acquisition, page 56

Ziff Davis, page 57

6. We note that you allocated 32% and 56% of the purchase consideration to intangible
assets and goodwill, respectively.  Please tell us, in detail, how you determined the fair
values of trade name, customer relationship, advertiser relationship and licensing
relationship intangible assets.

Protus, page 58

7. Regarding your accounting for your acquisition of Protus , please explain to us in detail
how you determined the fair values of the trade name  and customer relationship
intangible assets .

7. Goodwill and Intangible Assets, page 64

Intangible assets Subject to Amortization, page 65

8. We note you are amortizing your customer relationship intangible assets over a weighted
average period of 6.7 years.  Explain to us how you determine d the estimate d useful life
of your acquired customer relationship intangible assets.  Tell us your subscriber monthly
churn rate and explain to us your consideration of this when estimating  the useful life  of
the customer relationship intangible assets.  Also, with a vi ew towards clarifying
disclosure, tell us your methodology for amortizing your customer  relationship intangible
assets.  If you are amortizing on a straight -line basis, explain your rational for using this
methodology.

Ms. Kathleen M. Griggs
j2 GLOBAL, INC.
April 24, 2013
Page 3

 12. Stockholders’ Equity, page  74

Ziff Davis, Inc. Equity Incentive Plan, page 78

9. Please tell us and disclose the specific factors you considered in concluding that the put
right is within your control.

*    *    *    *

Please file all correspondence over EDGAR.  We urge all persons who are responsible
for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes
the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules
require.   Since the compa ny and its management are in possession of all facts relating to a
company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they
have made.

            In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from  taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Dean Suehiro , Senior Staff Accountant, at (202) 551 -3384 or Robert S.
Littlepage , Accountant Branch Chief , at (202) 551 -3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact Paul Fischer , Staff
Attorney, at 202 -551-3415 or me at (202) 551 -3810 with any other questions.

Sincerely,

/s/ Robert S. Littlepage  for

Larry Spirgel
Assistant Director