Mail Stop 3561

      	July 13, 2005

VIA U.S. MAIL AND FACSIMILE

Mr. Jack Ferguson
Treasurer and Interim Chief Financial Officer
PC Connection, Inc.
Rt. 101A 730 Milford Road
Merrimack, NH  03054

	Re:	Form 10-K for the Year Ended December 31, 2004
		Form 10-Q for the Quarterly Period Ended March 31, 2005
      File No. 000-23827

Dear Mr.Ferguson:

		We have reviewed your filings and have the following
comments.  We have limited our review to only your financial
statements and related disclosures and do not intend to expand our
review to other portions of your documents.  If you disagree with
a
comment, 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.    After reviewing your response,
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 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 10-K for the year Ended December 31, 2004

Controls and Procedures, page 36

1. We note your officers concluded that your disclosure controls
and
procedures were ". . . in the reasonable assurance level."  We
further noted your statement that "controls and procedures, no
matter
how well designed and operated, can provide only reasonable
assurance
of achieving their objectives . . ."  Please tell us and revise
future filings to state, if true, that your disclosure controls
and
procedures are designed to provide reasonable assurance of
achieving
their objectives and that your principal executive officer and
principal financial officer concluded that your disclosure
controls
and procedures were effective at the reasonable assurance level as
of
the end of the period covered by the report.   Reference is made
to
Item 307 of Regulation S-K.  See also Section II.F.4 of
Management`s
Reports on Internal Control Over Financial Reporting and
Certification of Disclosure in Exchange Act Periodic Reports, SEC.
Release No. 33-8238.

Financial Statements

Note 1. Summary of Significant Accounting Policies, page F-8

Revenue Recognition, page F-8

2. We note from your disclosure on page 8 that a confirmation of
shipment from manufacturers and/or distribution companies is
received
prior to recording revenue.  Please reconcile that disclosure with
the last sentence of the first paragraph of your policy disclosure
where you state that delivery is deemed to have occurred at the
point
in time when the product is received by the customer.  Clarify
whether revenue is recognized upon shipment of the product to the
customer as indicated on page 8 or when delivered.  Please show us
what your disclosure will look like revised.

3. Please tell us if the agency sales transactions recorded on a
net
sales basis represent the drop shipments discussed on page 8.  If
so,
please clarify this fact in your policy disclosure in future
filings
indicating how you record revenue for drop ship arrangements.
Further, please address whether you receive payments in advance of
shipments, when the title and significant risks and rewards of
ownership pass to the buyer and the form of affirmative acceptance
necessary for you to recognize revenues.

4. Please include a policy note in future filings discussing
expenses
classified within cost of sales specifically as it relates to your
inbound freight charges, purchasing and receiving costs,
inspection
costs, warehousing costs, internal transfer costs, and the other
costs of your distribution network.  Where you currently exclude a
portion of these costs from cost of sales:
* Disclose the amount and line item they are presented for each
period presented, and
* Disclose in Management`s Discussion and Analysis, that your
gross
margins may not be comparable to those of other entities, since
some
entities include all of the costs related to their distribution
network in cost of goods sold and others like you exclude a
portion
of them from gross margin, including them instead in a line item,
such as selling, general and administrative expenses.
5. We note that you receive reimbursements from some vendors based
upon the volume of purchases or sales of the vendors` products.
Please tell us and disclose in future filings whether you
recognize
the reimbursements as the milestones are achieved or if you accrue
the reimbursements.  If you apply the accrual method, please
explain
to us the factors you considered in determining the reimbursements
are probable and reasonably estimable.

Note 11. Income Taxes, page F-19

6. Please tell us and disclose in future filings the amount of the
adjustment made to the accrual for tax contingencies for each
period
presented.


*	*	*	*	*	*

      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 filings;
* 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 comment on your filing.

		Please respond to this comment within 10 business days,
or
tell us when you will provide us with a response.  Please file
your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
response to our comments.

      If you have any questions regarding these comments, please
direct them to Donna  Di Silvio, Staff Accountant, at (202) 551-
3202,
or in her absence, to the undersigned at (202) 551-3841.

						Sincerely,



								Michael Moran
								Branch Chief

??

??

??

??

Mr. Jack Ferguson
PC Connection, Inc.
July 13, 2005
Page 1