MAIL STOP 03-08
								June 16, 2005
Frank Khulusi
Chief Executive Officer
2555 West 190th Street
Suite 201
Torrance, CA  90504


      Re:	PC Mall, Inc.
		Form 10-K for the Fiscal Year Ended December 31, 2004
      Form 10-Q for the Quarterly Period Ended March 31, 2005
		File No. 0-25790


Dear Mr. Khulusi:

      We have reviewed your filings and have the following
comments.
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.  Please be as detailed as necessary in
your explanations.  Where indicated, we think you should revise
your
disclosures in future filings 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.  In some of our
comments,
we may ask you to provide us with information so we may better
understand your disclosure.  After reviewing this information, we
may
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 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 28

Critical Accounting Policies and Estimates, page 31

Deferred Advertising Revenue and Costs, page 32

1. We note your disclosure regarding your accounting policy for
market development funds and co-op advertising funds received from
vendors and of the costs to develop, produce and circulate your
catalogs.  Please provide us with the following additional
information:

* Clarify for us why market development and co-op advertising
funds
are not considered to be a reimbursement of costs to sell your
vendors` products;

* We presume that the term "co-op revenue" used in your disclosure
refers to co-op advertising funds.  Please explain to us why you
refer to market development and advertising funds as "revenue"
when
they have been offset to cost of sales;

* Clarify for us and revise your disclosure to indicate whether
deferred advertising costs related to the development, production
and
circulation of your catalogs and co-op revenue are recognized on a
straight-line basis over the estimated life of the catalog or
recognized based on sales generated over the life of the catalog;
and

* Your basis for estimating the life of your catalogs to be eight
weeks.

Year Ended December 31, 2004 Compared to the Year Ended December
31,
2003, page 33

2. Please explain why the adoption of EITF 02-16 impacted the
comparability of the years ended December 31, 2004 and 2003 since
this accounting standard was effective during both of these
periods.

3. In future filings, please quantify the amount of the increase
or
decrease attributed to each factor that contributes to material
changes over the reported periods.  For example, we note that you
provided various factors that may cause gross margins to
fluctuate,
but none of those factors are quantified for the changes over the
reported periods in question outside of the impact of the adoption
of
EITF 02-16.  Further examples of factors that should be quantified
in
future filings include the dollar impact of:

* the 30%, 17% and 2% increases in your outbound telemarketing
business, PC Mall Gov sales and retail sales, respectively, on
2004
net sales;

* the 29%, 11% and 15% increases in your outbound telemarketing
business, PC Mall Gov sales and retail sales, respectively, and
the
21% decline in catalog sales on 2003 net sales; and

* the increased expenses of operating your Canadian call center in
2004 on SG&A expense.

4. In future filings, please attribute all of the material changes
in
the reported periods to specific factors.  For example, we note
your
explanation of $1.5 million of the $7.1 million increase in 2004
SG&A
expenses for the eCOST.com segment and your explanation of
approximately $2.3 million of the $11.8 million increase in 2003
consolidated SG&A expenses, but you have not attributed the
remaining
increases to any other specific factors.

5. In future filings, please expand your discussion to describe
the
underlying causes of the changes in your results of operations and
provide a more detailed analysis of material year-to-year changes
and
trends.  For example, you should explain why the expenses of
operating your Canadian call center increased in 2004 and the
business purpose of the 2004 awards that resulted in the $1.5
million
of non-cash stock-based compensation expenses for the eCOST.com
segment.
For further guidance on management`s discussion and analysis of
results of operations, please refer to Item 303(a)(3) of
Regulation
S-K and our Interpretative Releases on Management`s Discussion and
Analysis, Release 33-8350 and Section III.D of Release 33-6835,
both
of which are available on our website at www.sec.gov.

Liquidity and Capital Resources, page 36

6. In future filings, please quantify and include a discussion of
all
relevant factors that directly contribute to material changes when
describing the change in net cash used in operating activities
over
reported periods and explain the underlying causes of changes in
cash
flow.   For example, we note that you discuss the increase in
accounts receivable as a primary factor in the change for 2004 as
compared with 2003, but you have excluded discussion of the
underlying cause of this change.  Furthermore, you have excluded
any
discussion of other significant factors such as the change in
inventory in 2003 and the change in accounts payable, accrued
expenses and other current liabilities in both 2004 and 2003.

7. In future filings, please discuss the operational reasons for
negative cash flows from operations and explain how you intend to
meet cash requirements and maintain operations.  For further
guidance
on management`s discussion and analysis of liquidity and capital
resources, please refer to Item 303(a)(1) of Regulation S-K and
the
Commission`s Interpretive Releases on MD&A, Release 33-8350 and
Section III.C of Release 33-6835, both of which are available on
our
website at www.sec.gov.

Contractual Obligations, page 37

8. In future filings, please revise to include all long-term
liabilities and any material employment contracts in your table of
contractual obligations.

Consolidated Financial Statements, page F-1

Report of Independent Registered Public Accounting Firm, page F-2

9. We note that your independent auditor`s report indicates that
your
ineffective control over the valuation and completeness of revenue
related to software service advisor agreements resulted in an
audit
adjustment to the 2004 consolidated financial statements.
Quantify
for us, the impact, if any, these agreements had on your results
of
operations and financial condition during 2003 and 2002.

Notes to Consolidated Financial Statements, page F-8

Property and Equipment, page F-11

10. We note your disclosure on page F-11 indicates that you have
equipment acquired under capital leases, yet you have not
disclosed
any capital lease obligations in Note 5 -  Commitments and
Contingencies to your consolidated financial statements.  Please
confirm that you either have no remaining capital lease
obligations
or that any obligations outstanding at December 31, 2004 are
immaterial.

Note 7. Employee Benefits, page F-19

Stock Warrants and Options Issued to Non-employees, page F-20

11. We note your disclosure related to the warrant to purchase
30,000
shares of the Company`s common stock which was issued to a
consulting
firm for investor and public relations services in June 2003 and
the
October 2004 option grant of 45,000 shares to a public relations
consultant.  Please confirm for us that you recorded an expense of
approximately $0.1 million in 2004 as a fair value re-measurement
adjustment for the June 2003 warrant grant.  Additionally, provide
us
the following information:

* Provide us with the details of the fair value calculation at the
date of grant for the warrant to purchase 30,000 shares and the
option to purchase 45,000 shares including the grant date fair
value
of your common stock, volatility, discount rate used and expected
term.

* Detail for us the amount expensed for each grant at inception
and
the fair value re-measurement adjustments recorded including the
underlying stock price at each re-measurement date for each
reporting
period up to the date the warrant and option fully vested.

Note 9. Segment Information, page F-23

12. Expand your disclosure in future filings to reconcile the
amounts
of eCOST.com`s 2004, 2003 and 2002 net sales, gross profit,
operating
income (loss) and total assets disclosed herein to the financial
statements included in eCOST.com, Inc.`s Form 10-K for the fiscal
year ended December 31, 2004 incorporated by reference into your
filing.

Schedule II - Valuation of Qualifying Accounts

13. In future filings, please include all qualifying accounts in
Schedule II.  For example, we note that the change in deferred tax
asset valuation allowance for 2002 was excluded from your 2004
Schedule II.

Form 10-Q for the Quarterly Period Ended March 31, 2005

General

14. Please include page numbers in all future filings.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Results of Operations for the Three Months Ended March 31, 2005
Compared to the Three Months Ended March 31, 2004

15. We note your disclosure related to a decrease in customer
demand
for certain high-value products.  Please tell us the amount of
inventory, if any, you wrote-down as a result of the decrease in
demand in anticipation of new product releases during the quarter
ended March 31, 2005.  If you did not write-down any inventory
during
the quarter, please explain why not.

* * * * *

       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 that provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  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 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 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 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 Scott Ruggiero at (202) 551-3331 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3716 with any other
questions.


Sincerely,


William Choi
Branch Chief


Mr. Frank Khulusi
PC Mall, Inc.
June 16, 2005
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