SecProbe.io

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Mail Stop 3561
								July 8, 2005
Adam W. Shaffer
Chief Executive Officer
2555 West 190th Street
Suite 106
Torrance, CA  90504

      Re:	eCOST.com, Inc.
		Form 10-K for the Fiscal Year Ended December 31, 2004
		File No. 0-25790

Dear Mr. Shaffer

      We have reviewed your response letter dated July 1, 2005 and
have the following comment.  We have limited our review only to
your
financial statements and related disclosures and do not intend to
expand our review to other portions of your documents.  Where
indicated, we think you should revise your disclosures in future
filings in response to this comment.  Please be as detailed as
necessary in your explanations.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.

	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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 35

Contractual Obligations, page 47

1. We note your response to our prior comment number 4.  However,
we
are not in a position to agree with your interpretation of
Regulation
S-K, Item 303(a)(5)(ii)(D).  We believe that employment agreements
meet the definition of a purchase obligation which is "an
agreement
to purchase goods or services that is enforceable and legally
binding
on the registrant that specifies all significant terms."  We
advise
you that we similarly believe material funding requirements for
pensions and other post employment benefits should be included in
the
table of contractual obligations.  Therefore, we believe that you
should include all material employment agreements in your
contractual
obligations table in future filings.  If the employment contracts
are
subject to variable compensation provisions, then you should
provide
estimates of the payments due and include footnotes to inform
investors of the payments that are subject to variability, if that
information is material to investors. In addition, the footnotes
should discuss any material termination or renewal provisions to
the
extent necessary for an understanding of the timing and amount of
your payments.

* * * * *

       Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please understand
that
we may have additional comments after reviewing your responses to
our
comments.

	You may contact Scott Ruggiero at (202) 551-3331 if you have
questions regarding this comment on the financial statements and
related matters.  Please contact me at (202) 551-3716 with any
other
questions.

Sincerely,

William Choi
Branch Chief

Mr. Adam W. Shaffer
eCOST.com, Inc.
July 8, 2005
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