SecProbe.io

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July 1, 2005

Via Facsimile and U.S. Mail

Richard N. Burger
Chief Financial Officer
Coleman Cable, Inc.
1530 Shields Drive
Waukegan, Illinois 60085

	Re:	Coleman Cable, Inc.
      Amendment No. 1 to Form S-4 filed June 22, 2005
      File No. 333-124334

Dear Mr. Burger:

      We have reviewed your amended 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.
We welcome any questions you may have about our comments or on any
other aspect of our review.  Feel free to call us at the telephone
numbers listed at the end of this letter.

Summary Consolidated Financial Data, page 7

1. Please revise footnote 7 to state the amount by which pro forma
fiscal year 2004 earnings were not sufficient to cover fixed
charges.
Also, please remove the ratios below 1.0.  Refer to Instruction 2
to
Item 503(d) of Regulation S-K for guidance.

2. We note your response to comment 9 in our letter dated May 23,
2005
and your revised disclosures.  You disclose that EBITDA is useful
to
investors because it "eliminates the effects of financing and
income
taxes, as well as the accounting effects of capital spending."
This
statement does not adequately explain to an investor why EBITDA is
a
useful measure.  Please revise your disclosure, as appropriate.
In
addition, please also revise your disclosure to state the economic
substance behind your decision to use EBITDA as a performance
measure,
as required by Question 8 of the SEC "Frequently Asked Questions
Regarding the Use of Non-GAAP Financial Measures."

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 32

Consolidated Results of Operations, page 34

3. Please revise your discussion of your gross profit margin for
the
interim periods ended March 31, 2005 and 2004 to quantify the
impact
of the inefficiencies related to the manufacturing consolidation,
as
well as to provide additional insight as to whether the
inefficiencies
are expected to continue in the future or have been corrected and
are
not expected to impact future periods.

4. Please revise your discussion of income tax expense to provide
a
reasonably detailed explanation as to why your effective tax rate
significantly increased for the three-month period ended March 31,
2005 to 90 percent when compared to the 19 percent effective tax
rate
for the three-month period ended March 31, 2004.

Liquidity and Capital Resources, page 40

5. We note your response to comment 24 in our letter dated May 23,
2005 and your revised disclosures to include information regarding
the
material debt covenants contained in your credit facility and
indenture to the Notes.  However, it does not appear that you have
revised your disclosure to provide a comprehensive discussion and
analysis of your sources and uses of cash, such as your historical
and
current financing arrangements, or any financial covenants as
noted on
pages 59-60.  As such, please revise your discussion to include
the
following:
* A discussion that clearly articulates why you believe cash flow
from
operations and borrowings under your senior secured credit
facility
will be sufficient to fund your operations, debt service and
capital
expenditures for the foreseeable future;
* A detailed description of your debt instruments and the amount
available under each instrument without violating any debt
covenants
for the most recent period presented;
* A description of your financial covenants, including actual
results;
and
* A statement that you were in compliance with all of your debt
covenants as of March 31, 2005, if true.
Please refer to Section IV.B. and IV.C. of the SEC Interpretive
Release No.      33-8350 dated December 19, 2003, Item 303.a.1. of
Regulation S-K, and Section 501.03 of the Financial Reporting
Codification for additional guidance.

Critical Accounting Policies, page 43

6. We note your response to comment 26 in our letter dated May 23,
2005 and your revised disclosures.  We note that you have not
revised
your disclosures related to your inventories and plant and
equipment
critical accounting estimates.  Please revise your disclosure to
provide the following information, or tell us how you determined
your
current disclosure fully complies with Item 303 of Regulation   S-
K:
      Inventories:
* Your method for evaluating inventory for obsolescence, damage
and/or
excess;
* The significant assumptions made by management; and
* The sensitivity of the assumptions used to estimate
obsolescence,
damage and/or excess.
* Plant and Equipment:  A sensitivity analysis regarding your
estimated useful lives by major asset category.
Goodwill:
* State the valuation method used to determine if goodwill is
impaired;
* A discussion of the assumptions used to estimate future cash
flows;
and
* The types of events that could result in an impairment to your
goodwill balance.
Refer to SEC Interpretive Release No. 33-8350, SEC Other Release
No.
33-8040 and SEC Proposed Release No. 33-8098 for additional
guidance.

Security Ownership, page 53

7. We have reviewed your response to our prior comment 30 in our
letter dated May 23, 2005.  Please include the information
provided in
that response in a footnote to the table.

Coleman Cable, Inc. consolidated financial statements for the year
ended December 31, 2004

5.  Goodwill and Intellectual Property

8. We note your response to comment 36 in our letter dated May 23,
2005.  However, it remains unclear why you are not required to
allocate goodwill to your operating segments in accordance with
SFAS
142.  Paragraph 30 of SFAS 142 states, "A reporting unit is an
operating segment or one level below an operating segment
(referred to
as a component).  A component of an operating segment is a
reporting
unit if the component constitutes a business for which discrete
financial information is available and segment management
regularly
reviews the operating results of that component."  Paragraph 54 of
SFAS 142 requires all goodwill recognized in an entity`s balance
sheet
at the date SFAS 142 is initially applied to be assigned to one or
more reporting units.  As such, it appears that goodwill must be
allocated to your operating segments.  Please refer to paragraphs
34
and 35 of SFAS 142 for guidance on allocating goodwill to your
operating segments and perform the appropriate impairment tests.

8.  Business Segment Information, page F-33

9. We note your response to comments 38 and 39 in our letter dated
May
23, 2005.  It remains unclear to us why you are not disclosing
fixed
asset depreciation and amortization expense by reportable segment,
since:
* It is not listed as an unallocable cost that is included within
Corporate, but rather is allocated to your operating segments
using
product costing;
* It is included in the determination of segment operating income,
which is disclosed by reportable segment; and
* Paragraph 90 of SFAS 131 states, "an enterprise may allocate
expense
to a segment without allocating the related asset; however,
disclosure
of that fact is required."
Please revise your disclosures accordingly.

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      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
for
an informed decision.  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.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Please direct questions regarding accounting comments to
Tracey
Houser at (202) 551-3736, or in her absence, to Jeanne Baker at
(202)
551-3691. Direct questions on other disclosure to Brigitte
Lippmann at
(202) 551-3713 or Chris Edwards at (202) 551-3742. In this regard,
please do not hesitate to contact the undersigned at (202) 551-
3760.

Sincerely,

Pamela A. Long
Assistant Director

cc:	George C. McKann, Esq.
	Gardner Carton & Douglas LLP
	191 North Wacker Drive
	Chicago, Illinois 60606

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Richard N. Burger
Coleman Cable, Inc.
July 1, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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