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    WWW.EXFILE.COM, INC. -- 888-775-4789 -- J2 GLOBAL COMMUNICATIONS, INC. -- CORRESPONDENCE

    January
7, 2010

    Larry
Spirgel

    Assistant
Director

    United
States Securities and Exchange Commission

    Washington,
D.C. 20549

    Dear Mr.
Spirgel:

    As Vice
President and General Counsel of j2 Global Communications, Inc. (“j2”), I am
sending you this letter in response to your comment letter to Nehemia Zucker,
Chief Executive Officer of j2, dated December 29, 2009.

    The
following is a list of the comments of the staff of the Securities and Exchange
Commission in italics, each followed by j2’s response to that
comment:

              1.

              It
      appears that you use the surveys listed on page 15 for benchmarking
      purposes.  For example, you disclose on page 16 that the
      compensation committee considers the surveys to help ensure that executive
      salaries remain in line with the Compensation Committee’s target
      range.  If you use surveys to benchmark total compensation, or
      any material element of compensation, you must identify the companies in
      the surveys.  See Regulation S-K Item
      402(b)(2)(xiv).  Please confirm in your response letter that you
      will comply with our comment in future filings where you use the surveys
      to benchmark your named executive officers’ compensation. For further
      guidance, see Question 11805 of the Division of Corporation Finance
      Regulation S-K Compliance and Disclosure Interpretations, available on our
      website at http://www.sec.gov/divisions/corpfin/cfguidance.shtml.

    Response: j2 hereby
confirms that it will comply with this comment in future filings, including but
not limited to complying with such comment in future filings where j2 uses
surveys to benchmark its named executive officers’ compensation.

              2.

              In
      future filings, please identify the outside benefits consulting firm the
      compensation committee retained and discuss the consultant’s role in the
      compensation-setting practices and decisions. See also our new rules
      relating to enhanced disclosure concerning compensation consultants
      effective February 28, 2010 (SEC Release
  34-61175).

    Response: j2 hereby
confirms that it will comply with this comment in future filings.

              3.

              We
      note that bonus awards paid to certain named executive officers are tied
      to the achievement of specified pre-established individual and company
      performance objectives.  In future filings, please disclose, for
      each named executive officer, the target payouts, the performance targets
      and threshold levels for each performance goal. Also disclose the extent
      to which the individual and company performance targets were
      met.  See Item 402(b)(v),(vi) and (vii) of Regulation
      S-K.

    Response: j2 hereby
confirms that it will comply with this comment in future filings.

    In
addition, j2 acknowledges that:

              ·

              it
      is responsible for the adequacy and accuracy of the disclosure in its
      filings with the Commission;

              ·

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

              ·

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

    Please
feel free to call or write me if you have any questions or
concerns.  My direct line is 323 860 9276.

    Sincerely,

    /s/ Jeffrey D.
Adelman

    Jeffrey
D. Adelman

    Vice
President and General Counsel

    cc:           Nehemia
Zucker, Chief Executive Officer