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      Q Comm International, Inc. Correspondence June 28, 2005

              June
                28, 2005

              VIA
                EDGAR

    Mr.
      Larry
      Spirgel

    Assistant
      Director

    Office
      of
      Small Business

    Division
      of Corporation Finance

    United
      States Securities and Exchange Commission

    450
      Fifth
      Street, N.W., Mail Stop 0407

    Washington,
      D.C. 20549

            Re:

              Q
                Comm International, Inc.

              Form
                10-KSB for the year ended December 31, 2004

              File
                No. 001-31718

    Dear
      Mr.
      Spirgel:

    This
      letter responds to the Staff’s comment letter dated June 14, 2005 regarding the
      above-referenced report filed by Q Comm International, Inc. (the “Company”). For
      ease of reference, your inquiries have been incorporated in this letter and
      precede our responses. If you have any questions regarding the responses to
      your
      comments, please feel free to call me directly at (801) 805-6012.

    Item
      6. Management’s Discussion and Analysis or Plan of
      Operations

    Sources
      of Revenue, page 16

            1.

              We
                note your prior response to comment #2. Please address paragraph
                9(b) of
                EITF 00-21 and how you determine the objective and reliable evidence
                of
                fair value for each of the deliverables. Note the fact that the contract
                states these amounts does not indicate fair value. Refer paragraph
                16 of
                EITF 00-21, In addition tell us how you determined these elements
                have
                fair value on a standalone basis.

    Terminals
      are sold separately, independent of any service bureau contracts. The pricing
      for the terminal sales is generally consistent whether sold to service bureau
      or
      non-service bureau customers. However, separating out each element, including
      installation, and maintaining detailed information for VSOE is problematic.
      As a
      result, we will recognize service bureau revenue derived from (1) terminal
      sales, (2) sales of proprietary software, and (3) installation services for
      the
      software, as bundled elements, ratably over the lives of the respective
      contracts, which are generally three years. Revenues derived from service bureau
      maintenance agreements and transaction fees are easily identified as separate
      elements with standalone fair values as determined by VSOE. These are billed
      monthly as earned and the associated revenue will continue to be recognized
      on a
      monthly basis.

    The
      table
      below presents the approximate impact of the revenue recognition methodology
      change. The amounts presented below are prior
      to
      the
      restatement that will be made for reporting our consignment PIN inventory sales
      using net reporting vs. gross reporting in accordance with EITF No.
      99-19.

              Year
                ended

              December
                31, 2004

              Per
                2004

              Form
                10-KSB

              Adjustment

              Adjusted

              Total

              Change

              Revenue

              40,801,000

              (175,000

              )

              40,626,000

              -0.43

              %

              Net
                loss

              (6,547,000

              )

              (70,000

              )

              (6,617,000

              )

              1.07

              %

              Shares
                outstanding

              4,345,016

              4,345,016

              Net
                loss per share

              (1.51

              )

              (1.52

              )

              -0.66

              %

              Quarter
                ended

              March
                31, 2005

              Per
                March 31,

              2005

              Adjusted

              Form
                10-Q

              Adjustment

              Total

              Change

              Revenue

              15,303,000

              (10,000

              )

              15,293,000

              -0.07

              %

              Net
                loss

              (1,296,000

              )

              (2,000

              )

              (1,298,000

              )

              0.15

              %

              Shares
                outstanding

              4,978,000

              4,978,000

              Net
                loss per share

              (0.26

              )

              (0.26

              )

              0.00

    We
      have
      reviewed the parameters of SAB No. 99 in detail and based on our assessment
      of
      both quantitative and qualitative factors, we have determined that the impact
      of
      these adjustments is not material to the Company’s consolidated financial
      statements for the year ended December 31, 2004 and the quarter ended March
      31,
      2005. For future filings, however, we will disclose our revenue recognition
      policy accordingly and record all service bureau transactions in accordance
      therewith.

    Critical
      accounting Policies and Estimates

    Revenue
      Recognition, page 19

            2.

              We
                noted your response to prior comment 3 as requested, please amend
                your
                Form 10-KSB and 10-QSB.

    We
      will
      amend our Form 10-KSB and Form 10-Q no later than August 10, 2005.

    Form
      10-QSB for quarterly periods ended March 31, 2005

              3.

              We
                note your response to prior comment 4 and your revision to the statement
                of operations. Please revise your Cost of goods line item to reflect
                either “Cost of goods sold (exclusive of items shown separately below)” or
                “cost of good sold (exclusive of depreciation shown separately
                below).”

              We
                will revise the cost of goods line in the statement of operations
                to
                reflect “Cost of goods sold (exclusive of items shown separately below)”
                in the amended Form 10-KSB and Form 10-Q. We are no longer eligible
                to use
                small business forms and our Form 10-Q filing for the three months
                ended
                March 31, 2005 and future periodic filings will be in accordance
                with
                Regulation S-X.

    Best
      regards,

/s/
      Mark W.
      Robinson

    Mark
      W.
      Robinson

    Chief
      Financial Officer

    Q
      Comm
      International, Inc.