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[ZUMIEZ LOGO]

March 30,
2005

H.
Christopher Owings, Assistant Director

Securities and Exchange Commission

Mail Stop 0308

450 Fifth Street N.W.

Washington, D.C. 20549

Re:Zumiez Inc.

Registration Statement on Form S-1

File No. 333-122865

Filed February 17, 2005

Dear
Mr. Owings:

        Zumiez Inc.
(the "Company") is hereby submitting Amendment No.1 to the above-referenced Registration Statement on Form S-1 (the "Amendment") for filing under
the Securities Act of 1933, as amended (the "Act"). The Amendment is marked to show revisions from the initial filing on Form S-1 and reflects revisions made in response to the
comments of the staff (the "Staff") of the Division of Corporation Finance of the Securities and Exchange Commission (the "Commission") in your comment letter dated March 16, 2005 (the "Comment
Letter") addressed to Brenda I. Morris, Chief Financial Officer of the Company.

        Below
we have reprinted each of the Staff's comments in bold and thereunder set forth our related response. Capitalized terms used herein have the same meanings as set forth in the
Amendment. Except with respect to page numbers originally referenced in your Comment Letter or unless otherwise noted, all page number references herein relate to pages in the prospectus contained
within the Amendment (the "Prospectus").

General

1.COMMENT: Please note that when you file a pre-effective amendment containing pricing-related information, we may have additional comments.
Also, please confirm that any preliminary prospectus that you circulate will disclose all non-Rule 430A information, including the price range and related information based on a
bona fide estimate of the public offering price within that range.

RESPONSE:
We have noted the Staff's comments and intend to disclose all non-Rule 430A information in any preliminary prospectus that we
circulate.

2.COMMENT: Please file as promptly as practicable all exhibits, particularly the legal opinion and underwriting agreement, as we will review them prior to
granting effectiveness of the registration statement. We may have further comments upon review of the exhibits.

RESPONSE:
We have noted the Staff's comment. Specifically, the Form of Legal Opinion (and related consent) of Preston Gates & Ellis LLP, counsel to
the Company, is filed as Exhibit 5.1 to the Amendment. A final, signed legal opinion (and related consent) will be filed after the completion of the reincorporation of the Company in the State
of Washington prior to consummation of the offering. This will confirm that the final legal opinion (and related consent) along with the form of Underwriting Agreement will be filed with a
pre-effective amendment to the Registration Statement.

3.COMMENT: Please provide us with the industry publications from which you have obtained statistical data, and to which you refer on page 41 and throughout your
Business section. Similarly, please provide us with support for the statement indicating that you are "a leading specialty retailer of action sports related apparel, footwear, equipment and
accessories" and all other statements regarding market leadership. Please mark your supplemental support or

 provide page references in your response to the sections upon which you rely. Tell us whether the information you cite from these reports is publicly available. If not, you should obtain appropriate
consent to cite these reports in your filing.

RESPONSE:
We have supplementally provided with this response letter copies of the industry publications from which we have obtained statistical data that is
included on page 39 of the Prospectus. This will confirm that all industry publications from which the Company has obtained statistical data and to which the Company refers in the Business section
were either (a) publicly available, or (b) cited with the written consent of the party that prepared such material. These supplemental materials are as follows:

•Board-Trac, Inc.,
2003 Size of the Market Report, 2003, page 7 (attached as Exhibit A to this
letter). •Press
Release, Teenage Research Unlimited, TRU Projects Teens Will Spend $169 Billion In 2004, December 1, 2004
(attached as Exhibit B to this letter). •SGMA
International, Sports Participation Topline Report, 2004 Edition, August 2004 (attached as Exhibit C to
this letter).

Additionally,
we will provide copies of these supplemental materials to the Staff under separate cover, marked to highlight the text in such industry
publications from which we have drawn statistical data included in the Prospectus.

This
will also supplementally advise the Staff that the Company bases its statements that the Company is "a leading specialty retailer of action sports
related apparel, footwear, equipment and accessories" and other statements regarding market leadership within the Prospectus on the following premises:

•We
believe the following list reflects the largest companies that are properly categorized as specialty retailers for action sports related apparel and gear along with the
approximate number of
retail stores they currently operate in the U.S. (based on publicly available information): Pacific Sunwear of California, Inc. (828 PacSun and PacSun outlet stores); Zumiez Inc. (140
stores); Quiksilver, Inc. (67 stores); and Tilly's, Inc. (40 stores). •Of
this group, the Company is the second largest retailer (measured in terms of retail outlets). •We
do not consider large format sporting goods stores such as Big 5 Sporting Goods Corporation, Dick's Sporting Goods, Inc., Sport Chalet, Inc. and The Sports
Authority Inc., to be in the same category of specialty retailers of action sports related apparel and gear, although the Company identifies these retailers in the Prospectus under the heading
"Competition" in the Business section of the Prospectus. •Similarly,
we do not consider general teenage-focused retailers such as Abercrombie & Fitch, Aeropostale, Inc. and American Eagle Outfitters, Inc., that
focus more on general apparel and fashion, to be within the category of specialty retailers of action sports related apparel and gear, although the Company identifies these retailers (among others) in
the Prospectus under the heading "Competition" in the Business section of the Prospectus.

Based
on the foregoing, the Company believes that it can substantiate the statements within the Prospectus indicating position as a market leader within the
referenced market, including the statement that it is "a leading specialty retailer of action sports related apparel, footwear, equipment and accessories."

4.COMMENT: Please tell us what exemption from registration Zumiez Holdings will rely on to distribute securities immediately prior to the initial public
offering.

2

RESPONSE:
Immediately prior to the initial public offering, Zumiez Holdings will transfer the shares of the Company's common stock that it holds to
Mr. Campion, the Company's Co-Founder and Chairman, Mr. Brooks, the Company's President and CEO, Mr. Haakenson, a Co-Founder of the Company, and
Brentwood-Zumiez Investors, LLC, pursuant to the terms of the Zumiez Holdings LLC Agreement. The shares that will be transferred by Zumiez Holdings prior to the initial public offering were acquired
by Zumiez Holdings in 2002 and will be transferred to such persons under the terms of the Holdings LLC Agreement for no consideration. Thus, there will be no sale of such shares in connection with the
distribution.

Prospectus Cover Page

5.COMMENT: Please delete the phrase "Joint Book Running Managers" from the prospectus cover page. You may, however, include this phrase, with a brief explanation,
to describe the syndicate's specific function, in the Underwriting section.

RESPONSE:
The Prospectus has been revised to reflect the Staff's comments. Please see the Prospectus cover page and page 68 of the Prospectus.

Certain Terms Used in this Prospectus, page ii

6.COMMENT: Please delete the entire section as the information provided here is either unnecessary or redundant. For example, the disclosure on what "Zumiez,"
"we," and "us" denote is evident from the context. Also, the information related to comparable store sales, gross square footage, and Internet sales appears in the footnotes on page 7, where the terms
are first discussed in the prospectus. In addition, the disclosure on the change of your fiscal year and its effects on your financial statements is appropriately located in the introductory
paragraphs of the Management's Discussion and Analysis section on page 26. You may explain the connotation of "SKU" where you first use that term on page 42. Also, please relocate the paragraph
beneath the table of contents.

RESPONSE:
We have revised this section to delete information that may be unnecessary or redundant. In this regard, we have deleted the disclosure about
references to Zumiez Inc. and the definition of "SKU," which we have relocated to page 40 of the Prospectus where the term "SKU" is first used. However, we believe that it is helpful to
investors to highlight the information related to comparable store sales, gross square footage, Internet sales and gift card sales at the beginning of the Prospectus, especially given that there are
variations in the way which some of our competitors and other apparel retailers calculate or present this information. Additionally, we believe that it is important to highlight for investors early in
the Prospectus that we changed our fiscal year after the year ended December 31, 2002, and that due to such change in our fiscal year certain financial data discussed in the Prospectus Summary
and elsewhere, such as compound annual growth rate and annual percentage changes in our comparable store net sales, do not take into consideration the one month transition period that began on
January 1, 2003 and ended on February 1, 2003.

We
have relocated the paragraph that appeared beneath the table of contents to page ii of the Prospectus above the section titled "Certain Terms Used in
this Prospectus."

Prospectus Summary, page 1

7.COMMENT: Please revise the summary to describe briefly the salient features of your business and the key aspects of this offering, and provide the detailed
information on these aspects in the Business section. At present, the summary is too lengthy and repetitive of information that is disclosed later in the prospectus. For example, the entire discussion
on pages 1-2 under the sub-heading Zumiez Inc. is repeated verbatim in the Business section,

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 and much of the language in the Competitive Strengths, Growth Strategy, and The Action Sports Market sub-sections in the summary and the Business section are identical. Delete the
discussion of competitive strengths, growth strategies, and the action sports market since it is more appropriate for the Business section.

RESPONSE:
In accordance with your request, we have revised the Prospectus Summary to eliminate certain information that was repetitive with the Business
section. We have attempted to limit the Prospectus Summary to provide salient features of the Company's business and key aspects of the offering. For example, the language in the Prospectus Summary
that addresses Competitive Strengths and Growth Strategy are short summaries of the more fulsome discussion of such points contained in the Business section. In addition, in connection with our
discussion of Competitive Strengths in the Prospectus Summary, we have included cautionary and balancing language so that readers may view this discussion in the appropriate context. Please see pages
1 and 2 of the Prospectus.

Risk Factors, page 8

8.COMMENT: In the first paragraph in italics, please revise the clause "the risks described below are not the only risks that we face" to make clear that you have
identified all material risks known to you and anticipated by you at present.

RESPONSE:
The Prospectus has been revised to reflect the Staff's comments. Please see page 7 of the Prospectus.

The terms of our revolving credit facility impose operating and financial restrictions…, page 12

9.COMMENT: Please identify Bank of America as the lender with which you currently have a revolving credit facility, and also disclose the effects of your
breaching financial covenants in fiscal 2002.

RESPONSE:
The Prospectus has been revised to reflect the Staff's comments. Please see pages 11 and 12 of the Prospectus. In fiscal 2002, as a result of the
closing of the Brentwood transaction, we were in breach of a debt to net worth covenant contained in a prior credit facility. Specifically, the facility required that we maintain a debt to worth ratio
requirement of 1.5:1, however, our actual ratio at December 31, 2002 was 1.56:1. We obtained a waiver from the lender under the facility and there were no adverse consequences to us as a result
of the violation.

Most of our merchandise is produced by foreign manufacturers…, page 14

10.COMMENT: Please quantify the percentage of purchases that are denominated in U.S. dollars.

RESPONSE:
The Prospectus has been revised to reflect the Staff's comments. Please see page 13 of the Prospectus, where we have noted that all of the
Company's merchandise purchases are denominated in U.S. dollars.

Purchasers in this offering will immediately experience substantial dilution…, page 18

11.COMMENT: Please revise to compare the net book value per share after the offering to the initial offering price.

RESPONSE:
The Prospectus has been revised to reflect the Staff's comments. Please see page 17 of the Prospectus. We note that the actual amount of dilution
in net tangible book value will be included in a pre-effective amendment to the Registration Statement.

4

Washington law and our articles of incorporation and bylaws, page 18

12.COMMENT: Please amplify your risk factor heading to disclose the risk to your shareholders that the anti-takeover provisions may prevent or
frustrate attempts to replace or remove the current management of the company by shareholders, even if the takeover may be in their best interests.

RESPONSE:
The Prospectus has been revised to reflect the Staff's comments. Please see page 18 of the Prospectus.

Cautionary Note Regarding Forward-Looking Statements and Market Data, page 20

13.COMMENT: Please delete the sentence: "All statements other than statements of historical facts…are forward-looking statements." You may, however,
state to the effect that statements that reflect your current views with respect to future events and financial performance, and any other statements of a future or forward-looking nature are
forward-looking statements for the purposes of federal securities laws.

RESPONSE:
The Prospectus has been revised to reflect the Staff's comments. Please see page 19 of the Prospectus.

14.COMMENT: As you are responsible for the accuracy and completeness of the contents of the registration statement, please delete the last
paragraph.

RESPONSE:
The Prospectus has been revised to reflect the Staff's comments. We have deleted the last sentence contained in the last paragraph under the
heading Cautionary Note Regarding Forward-Looking Statements and Market Data. We believe that the balance of the paragraph is an accurate statement and does not imply that the Company is not
responsible for the accuracy and completeness of the contents of the Registration Statement. Please see page 19 of the Prospectus.

Use of Proceeds, page 21

15.COMMENT: Please provide a more meaningful description of "general corporate purposes," by breaking down the category into sub-components such as
general and administrative expenses, and the like.

RESPONSE:
The Prospectus has been revised to reflect the Staff's comments. Please see page 20 of the Prospectus.

16.COMMENT: Please quantify the approximate dollar amount of proceeds that you intend to use for each of the purposes you have identified.