Mail Stop 3561
									December 9, 2005


Mr. Dan Crow
Vice President and Chief Financial Officer
Hastings Entertainment, Inc.
3601 Plains Boulevard
Amarillo, Texas 79102

		RE:	Hastings Entertainment, Inc.
			Form 8-K Filed December 8, 2005
			File No. 000-24381

Dear Mr. Crow:

      We have reviewed your filing and have the following comment.
Where indicated, we think you should revise your document in
response
to this comment. 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.

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

Form 8-K

Item 4.02(a)

1. Please amend your filing to clarify that it is management`s
position that your historical cash flows presentation did not
comply
with GAAP, and accordingly, you are amending your historical
filings
to comply with GAAP.  It is not appropriate to suggest that it is
the
Staff`s position, as opposed to management`s position, that
revisions
to the financial statements were required, as the fair
presentation
of the financial statements is the responsibility of management
and
not the Staff.

*    *    *    *

      As appropriate, please amend your filing and respond to this
comment within 5 business days or tell us when you will provide us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please understand that we
may
have additional comments after reviewing your amendment and
response
to our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

	In connection with responding to this comment, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Adam Phippen, Staff Accountant, at (202)
551-
3336.  In his absence, direct your questions to Robyn Manuel at
(202)
551-3823.  Any other questions may be directed to me at (202) 551-
3843.

								Sincerely,



								George F. Ohsiek, Jr.
								Branch Chief



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Mr. Dan Crow
Hastings Entertainment, Inc.
December 9, 2005
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