SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>qcommletter.txt
<DESCRIPTION>ITEM 4 FORM 8-K FILED 9/10/04 COMMENT LETTER SENT 9/14/04
<TEXT>

					September 14, 2004

Mail Stop 0409

VIA U.S. MAIL AND FAX (801) 222-9555

Michael K. Openshaw
Chief Financial Officer
Q Comm International, Inc.
510 East Technology Avenue, Building C
Orem, Utah 84097

RE:	Q Comm International, Inc.
	Form 8-K filed September 10, 2004
            File No. 1-31718

Dear Mr. Openshaw:

We have reviewed your filing 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 or may not 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 on any other aspect
of our review.

1. Please revise the Form to state the specific date that the former
accountant resigned, declined to stand for re-election or was
dismissed, as required by Item 304(a)(1)(i) of Regulation S-B.

2. Item 304(a)(1)(ii) of Regulation S-B requires a statement whether
the accountant`s report on the financial statements for either of the
past two years contained an adverse opinion or a disclaimer of
opinion or was modified as to uncertainty, audit scope or accounting
principles; and a description of the nature of each such adverse
opinion, disclaimer of opinion or modification.  Please revise to
include disclosure of uncertainty regarding the ability to continue
as a going concern in the accountant`s report.

3. Revise to provide the information required by Item
304(a)(1)(iv)(B) of Regulation S-B, regarding any reportable event
(i.e. internal control weakness, etc.) that the former accountant
advised the company of during the two most recent fiscal years and
subsequent interim period through the date of termination.

Amend the report to include all of the information required by Item
304 of Regulation S-B.  Include a letter from the former accountants
addressing the revised disclosures.   File the amendment under cover
of Form 8-K/A and include the ITEM 4 designation, including the
letter from the former accountant filed as an Exhibit 16.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  Since the
company 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 connection with responding to our comments, please provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

Please provide the supplemental information requested above within 10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The
amendment requested should be filed as promptly as possible and
should be reviewed by the former accountants.  The letter required by
Exhibit 16 should cover the revised disclosures.

You may reach me at (202) 824-5336 with any questions.

						Sincerely,

						Rachel T. Zablow
						Staff Accountant

Q Comm International, Inc.
September 14, 2004

Page 1

</TEXT>
</DOCUMENT>