LADENBURG THALMANN & CO. INC.

                                December 18, 2006

VIA EDGARLINK AND FACSIMILE
- ---------------------------

Peggy Fisher, Assistant Director
Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 6010
Washington, D.C.  20549

         Re:      Universal Power Group, Inc.
                  Registration Statement on Form S-1
                  File No. 333-137265

Dear Ms. Fisher:

     Pursuant  to Rule 461 under the  Securities  Act of 1933,  as amended  (the
"Securities Act"), the undersigned, Ladenburg Thalmann & Co. Inc. and Wunderlich
Securities,  Inc.  (the  "Underwriters"),  as the  Underwriters  of the offering
pursuant  to the  above-captioned  Registration  Statement,  hereby  join in the
request  of  Universal  Power  Group,  Inc.  that  the  effective  time  of  the
above-captioned Registration Statement be accelerated to 4:15 p.m. Eastern Time,
on December 20, 2006, or as soon thereafter as practicable.

     In connection with this acceleration request and pursuant to Rule 460 under
the  Securities  Act, the following  information is provided with respect to the
distribution to date of the preliminary prospectus dated November 30, 2006:

   TO WHOM DISTRIBUTED                                      NUMBER OF COPIES
   -------------------                                      ----------------
   Retail brokerage offices                                     2,150
   Institutions (including prospective underwriters)              200
   Total                                                        2,350

         With respect to Rule 15c2-8 under the Securities  Exchange Act of 1934,
as  amended,  we wish to  advise  the  Commission  that  the  Underwriters  have
distributed or will distribute copies of the preliminary  prospectus at least 48
hours  prior to the  date it is  expected  that  confirmations  of sale  will be
mailed. Selected Dealers, if any, will represent that they will comply with Rule
15c2-8.

         The Commission is advised that the amount of compensation to be allowed
or paid to the Underwriters,  to be disclosed in the Registration  Statement, as
amended,  will not  exceed  an amount  that has been  approved  by the  National
Association of Securities Dealers, Inc.

                                    Very truly yours,

                                    LADENBURG THALMANN & CO. INC.
                                    WUNDERLICH SECURITIES, INC.

                                           /s/ Robert Kropp
                                      ------------------------------------
                                         LADENBURG THALMANN & CO. INC.

                                         By: Robert Kropp