Mail Stop 0407
      							May 10, 2005

Via U.S. Mail and Fax (781) 904-5605
Ms. Karen Walker
Vice President and Chief Financial Officer
Boston Communications Group, Inc.
55 Middlesex Turnpike
Bedford, MA  01730

	RE:	Boston Communications Group, Inc.
      Form 10-K for the fiscal year ended December 31, 2004
		Filed March 16, 2005
		File No. 0-28432

Dear Ms. Walker:

      We have reviewed the above referenced 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.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.  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.



2. Summary of Significant Accounting Policies

	Cash, Cash Equivalents and Short-Term Investments, page 41

1. We note your response to our prior comment 4 and your statement
that MARS are auctioned in the open market approximately every 28
to
35 days.  Considering that you evaluate your position on these
securities with predictable frequency and at known intervals, it
appears that your MARS securities are generally used with the
objective of generating profits on short-term differences in
price.
Please revise or advise.

	Impairment of Long-Lived Assets, page 43

2. We note your response to our prior comment 5.  It appears that
you
have concluded that no impairment condition has occurred that
would
require testing of long-lived assets for recoverability.  Although
the timing of the loss of revenues from Verizon and Cingular was
unclear as of December 31, 2004, the loss of revenues from these
major customers over the next twelve months appeared to be more
likely than not and could only be offset by the acquisition of
comparable sized customers.  Therefore an impairment condition
appears to have occurred, which would necessitate a SFAS 144
impairment testing.  Your impairment testing should account for
estimated future cash flows to test the recoverability of the
asset
group over its remaining life, including any reasonable cash flows
that you expect from Verizon and Cingular during that period.
Refer
to paragraph 18 of SFAS 144.  Please revise or advise.

11. Segment Reporting and Discontinued Operations, page 56

3. We note your response to our prior comment 8.  Tell us the
goodwill amounts allocated to the Voyager Billing and Prepaid
Wireless Segment.  Tell us, and disclose, any significant changes
in
the allocation of goodwill subsequent to the realignment of your
reporting units.  Finally, tell us why you believe it is
appropriate
to aggregate your Prepaid Wireless Services component and Prepaid
Systems component.


*    *    *    *







      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested supplemental information.  Please file your response
letter
on EDGAR.

      You may contact Kathryn Jacobson, Staff Accountant, at (202)
551-3365 or Kyle Moffatt, Accountant Branch Chief, at (202) 551-
3836
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3810 with any
other questions.

							Sincerely,



							Larry Spirgel
							Assistant Director



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Ms. Karen Walker
Boston Communications Group Inc.
May 10, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE