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EPLUS INC Regulatory Filings 2016

May 2, 2016

31729_rns_2016-05-02_7175e73e-3200-42f7-a0ba-31281a0c7ef8.zip

Regulatory Filings

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CORRESP 1 filename1.htm Licensed to: ePlus inc. Document created using EDGARfilings PROfile 4.0.0.0 Copyright 1995 - 2016 Summit Financial Printing, LLC. All rights reserved.

Elaine D. Marion

Chief Financial Officer

(O) 703-984-8040

(F) 703-984-8640

[email protected]

May 2, 2016

BY EDGAR AND U.S.P.S.

Mr. Stephen G. Krikorian

Accounting Branch Chief

Office of Information Technologies and Services

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: ePlus inc. Form 10-K for the fiscal year ended March 31, 2015 Filed May 29, 2015 File No. 001-34167

Dear Mr. Krikorian:

This letter is submitted by e Plus inc. (the " Company ") in response to the comments of the staff (the " Staff ") of the Division of Corporation Finance of the Securities and Exchange Commission (the " Commission ") with respect to the Company's Form 10-K for the fiscal year ended March 31, 2015 (the " Form 10-K "), as set forth in your letter to Phillip G. Norton dated April 19, 2016.

For your reference, the text of each comment contained in your letter has been reproduced herein, followed by the Company's response.

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

Results of Operations, page 34

  1. In your response to prior comment 6, you indicate that you analyze revenues by customer end market and by manufacturer, as opposed to discrete product and service categories. However, your current operating results discussion does not appear to reflect management's approach to analyzing revenues. Please tell us what consideration you gave to providing a discussion of revenues by customer end market and by manufacturer, including an analysis of the reasons for changes thereto.

RESPONSE: We advise the Staff that we will include an analysis of revenues by customer end market and by manufacturer, including an analysis of the reasons for changes thereto, in the operating results section of our Management's Discussion and Analysis in future filings beginning with our upcoming Form 10-K for the fiscal year ended March 31, 2016.


Please contact the undersigned at (703) 984-8040 with any further comments or questions you may have.

/s/ Elaine D. Marion
Elaine D. Marion
Chief Financial Officer
cc: Mr. Phillip G. Norton
Lloyd H. Spencer, Esq.

e Plus inc. 13595 Dulles Technology Drive Herndon, VA 20171 (703) 984-8400 www. e plus.com