SecProbe.io

CORRESP
1
filename1.htm

      Q Comm International Correspondence July 12, 2005

              July
                12, 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 provides the additional information you requested to supplement the
      Friday, July 1, 2005, telephone call with the Staff related to Q Comm
      International, Inc.’s service bureau revenue recognition accounting.
      Specifically, the Staff responded that the Company’s method for recognizing
      revenue for its service bureau business was appropriate and no restatement
      of
      service bureau revenue was needed. The following summarizes the key points
      of
      our service bureau model and revenue recognition accounting.

    Service
      bureau customers are those who license the Company’s proprietary software,
      install and maintain the software on their server hardware, and purchase
      terminals to install in third-party retail establishments they secure. In the
      service bureau contracts, the Company separately identifies fees for software
      licensing, installation and set-up, terminals, on-going maintenance support,
      and
      on-going fees based either on transaction volume or revenue processed through
      the system. All fees are negotiated separately for each customer and are based
      on the market value of the services, software or terminals provided. There
      are
      separate charges for services rendered (i.e., we do not “bundle” services with
      the cost of the terminals). There is no right of return, or additional
      obligation on the part of the Company once the terminals are sold. Terminals
      are
      typically sold on a cash basis. Once the software is installed there is no
      future obligation on the part of the Company for software upgrades and there
      are
      no rights of return for the software. Software revenue is recognized upon the
      sale (licensing) and installation of the software. Maintenance fees are billed
      monthly and the maintenance contract can be cancelled at anytime by the
      customer. Revenue from maintenance fees is recognized monthly as earned. Service
      bureau revenue totaled $347,273 for 2004, down from $414,123 for 2003, and
      is
      becoming a decreasing portion of our business.

    We
      trust
      that this summary will provide you with the confirmation of the facts that
      you
      need to conclude our discussion of this issue. If you have any further
      questions, please call me at the number set forth above.

    Best
      regards,

    Mark
      W.
      Robinson

    Chief
      Financial Officer

    Q
      Comm
      International, Inc.