Mail Stop 0306

March 31, 2005



Via U.S. Mail and Fax

Mr. Brian H. Davis
Vice President, Chief Financial Officer and Controller
IEC Electronics Corp.
105 Norton Street
Newark, NY 14513

	Re:	IEC Electronics Corp.
		Form 10-K for the fiscal year ended September 30, 2004
Filed November 17, 2004
Quarterly Report on Form 10-Q for the quarter ended December 31,
2004
      File No. 000-06508


Dear Mr. Davis:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
documents 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.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	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 on 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 September 30, 2004

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Analysis of Operations - Page 11

1. We note that selling and administrative expenses decreased by
$0.5
million in fiscal 2004 compared to fiscal 2003 "in spite of an
upgrade to [your] direct sales force as well as the addition of a
new
Vice President of Sales and Marketing."  We also note that selling
and administrative expenses decreased in fiscal 2003 compared to
fiscal 2002 partially due to a reduction in the number of
employees
and revenues decreased due to a reduction in business from a major
customer.  In future filings separately quantify and discuss
significant changes in financial statement amounts to the extent
practicable.  Additionally, identify and disclose known trends,
events, demands, commitments and uncertainties that are reasonably
likely to have a material effect on financial condition and
operating
performance.  Refer to SEC Release Nos. 33-8350, 34-48960, and FR-
72.

2. Significant changes in balance sheet amounts (e.g. cash,
accounts
receivable, inventories, debt, etc.) should also be addressed in
future filings.

Restructuring Charge (Benefit) - Page 12

3. Please expand future MD&A to make quantified disclosure about
anticipated and actual cost savings derived from your
restructuring
efforts during the periods presented.  Significant variances
between
anticipated and actual savings should be disclosed, including the
$240,000 reduction in the reserve for the Arab, Alabama facility,
and
the reasons for (and anticipated impact of) these variances
discussed.  Your disclosures should fully conform to the guidance
set
forth in the Question under "Disclosures" to SAB Topic 5-P.  Refer
to
the next to last paragraph to the referenced Question.

4. Please expand future MD&A to identify the periods in which
material cash outlays are anticipated and the expected source of
their funding. You should also discuss material revisions to exit
plans, exit costs, or the timing of the plan`s execution,
including
the nature and reasons for the revisions.  Refer to SAB Topic 5-P.

Liquidity and Capital Resources - Page 13

5. Revise future filings to include a discussion of liquidity on a
short-term and long-term basis under Instruction 5 to Item 303(a)
of
Regulation S-K.  Set forth the expected impact on liquidity from
significant trends, demands and commitments, equipment purchases,
future acquisitions and maturity of long-term debt.


Item 9A. Controls and Procedures - Page 20

6. We note your disclosure that your "Chief Executive Officer and
Chief Financial Officer, concluded that IEC`s disclosure controls
and
procedures are effective as of the end of the period covered by
the
Annual Report on 10-K to provide reasonable assurance that
information required to be disclosed by IEC in the reports that it
files or submits under the Exchange Act is recorded, processed,
summarized and reported within the time period specified in the
SEC
rules and forms."  Revise future filings to clarify, if true, that
your officers concluded that your disclosure controls and
procedures
are also effective to ensure that information required to be
disclosed in the reports that you file or submit under the
Exchange
Act is accumulated and communicated to your management, including
your chief executive officer and chief financial officer, to allow
timely decisions regarding required disclosure.  See Exchange Act
Rule 13a-15(e).

Financial Statements - Page 24

General

7. Please include Schedule II as required by Rule 5-04 of
Regulation
S-X for the allowance for doubtful accounts and any other
applicable
valuation and qualifying accounts in future filings.
Alternatively,
the information may be provided in the notes to the financial
statements.

Consolidated Statements of Operations - Page 26

8. In future filings please reclassify forgiveness of accounts
payable to operating income or tell us supplementally why you
believe
it should be classified as non-operating income, citing applicable
literature.  We may have further comments after reviewing your
response.

Consolidated Statements of Comprehensive Income  (Loss) and
Shareholders` Equity - Page 27

9. Please explain supplementally why the accumulated currency
translation adjustments were not recognized upon the disposition
and
closure of the Mexico operations in accordance with paragraph 14
of
SFAS 52.

Note 1. Business and Summary of Significant Accounting Policies -
Page 29

Revenue Recognition - Page 29

10. We see your current revenue recognition disclosures that you
recognize revenue upon product shipment but believe that these
policies should be more specific. The policies should address
transfer of title, evidence of an arrangement, the extent of any
customer acceptance, installation, training or other post shipment
obligations, rights of return, etc. and how these impact revenue
recognition. Refer to SAB 104.  Please address in future filings.

Long-Lived Assets - Page 29

11. In future filings please disclose in the notes and in MD&A the
factors leading you to conclude that the assets were impaired.
For
example, revise future filings to discuss the impairment
indicators
you reviewed and the assumptions you relied upon in your analyses.
Refer to paragraph 26 of SFAS 144.  Also, paragraph 7 of SFAS 144
indicates the carrying amount of a long-lived asset (asset group)
is
not recoverable if it exceeds the sum of the undiscounted cash
flows
expected to result from the use and eventual disposition of the
asset
(asset group).  Please revise the notes to your financial
statements
in future filings to clearly indicate that how you assess and
measure
impairments complies with SFAS 144.

Note 5. Restructuring - Page 32

12. In future filings please disclose the number of employees
included in the workforce reductions.

13. In future filings, beginning with the period in which an exit
plan is initiated, until the exit plan is completed, provide the
following disclosures required by SFAS 146:
a. A description of the exit or disposal activity, including the
facts and circumstances leading to the expected activity and the
expected completion date;
b. For each major type of cost associated with the activity (for
example, one-time termination benefits, contract termination
costs,
and other associated costs):
1) The total amount expected to be incurred in connection with the
activity, the amount incurred in the period, and the cumulative
amount incurred to date
2) A reconciliation of the beginning and ending liability balances
showing separately the changes during the period attributable to
costs incurred and charged to expense, costs paid or otherwise
settled, and any adjustments to the liability with an explanation
of
the reason(s) therefor
c. The line item(s) in the income statement or the statement of
activities in which the costs in (b) above are aggregated; and
d. If a liability for a cost associated with the activity is not
recognized because fair value cannot be reasonably estimated, that
fact and the reasons therefor.

14. In future filings provide a tabular reconciliation of material
exit and involuntary termination charges for each balance sheet
presented.  Your disclosures should fully conform to the guidance
set
forth in the Question under "Disclosures" to SAB Topic 5-P.  Refer
to
the last paragraph to the referenced Question.



Note 8. Shareholders` Equity: Stock-Based Compensation Plans -
Page
34

15. The stock-based compensation disclosures of FAS 148 paragraph
2(e) should be included in the "Summary of Significant Accounting
Policies" footnote.  Additionally, the table should include the
stock-based employee compensation cost, net of related tax
effects,
that would have been included in the determination of net income
if
the fair value based method had been applied to all awards.
Please
revise in future filings.

Exhibit 10.14

16. We note that per the termination agreement, the Company will
"direct the Transfer Agent to remove all restrictive legends
currently on [Mr. Anderson`s] stock certificates for 50,000
shares."
Supplementally explain whether you accelerated the vesting on the
shares, the accounting for the acceleration and the amount of
stock-
based compensation recognized.  Please disclose in future filings,
if
applicable.

17. We note that you granted a $60,000 loan to Mr. Anderson in
lieu
of his exercising stock options.  Please disclose this loan to a
related party in future filings and state separately on the face
of
the balance sheet.  Refer to Rule 5-02(3) of Regulation S-X.

Form 10-Q for the quarterly period ended December 31, 2004

Notes to the Financial Statements - Page 6

Note 5.  Restructuring - Page 8

18. We see that during May 2004 you commenced a restructuring
initiative in an attempt to more closely align resources to
customer
requirements and during the first quarter of 2005 you paid (and
expensed) $53,000 in severance and hiring costs related to this
initiative.  Please demonstrate supplementally how the accounting
and
presentation of these costs complied with SFAS 146.  Also, why are
hiring costs labelled as restructuring.  Note our concerns when
preparing future filings.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
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 file your cover letter on EDGAR.  When sending supplemental
information regarding this filing, please include the following
ZIP+4
code in our address: 20549-0306.  Please understand that we may
have
additional comments after reviewing your 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.

	In connection with responding to our comments, 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 disclosures in response to staff
comments in the filings reviewed by the staff 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 connection with our review of
your
filing or in response to our comments on your filing.

      You may contact Lynn Dicker, Staff Accountant, at (202) 824-
5264 or me at (202) 942-1812 if you have questions regarding
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Brian Cascio, Accounting Branch Chief, at
(202) 942-1791.


					Sincerely,



					Jay Webb
					Reviewing Accountant
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Mr. Brian H. Davis
IEC Electronics Corp.
March 31, 2005
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