Mail Stop 0308

							November 12, 2004


Daniel Tonissen
Chief Financial Officer
EZCORP, Inc.
1901 Capital Parkway
Austin, Texas  78746


	RE:	EZCORP, Inc.
		Item 4.01 Form 8-K filed October 12, 2004
            	File No. 0-19424


Dear Mr. Tonissen:

	    We have reviewed the above referenced filing and have the
following comments.  We welcome any questions you may have about
our
comments.  Feel free to contact us at the telephone numbers listed
at
the end of this letter.

1. We believe that the facts indicated in your filing represent a
future dismissal of Ernst & Young.  You will need to file an
amendment to this Form 8-K when Ernst & Young is no longer serving
in
any capacity as your principal accountant.  The amended Form 8-K
should disclose this date and state that there are still no
disagreements, if true.  The amendment should also include an
updated
letter from Ernst & Young indicating whether or not they agree
with
the disclosures in the amendment.

2. We suggest the amendment indicate you dismissed Ernst & Young
rather than saying they were terminated.  "Dismissed" is the term
specified in Rule 3-04 of Regulation S-X.


      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing 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.




EZCORP, Inc.
November 12, 2004
Page 2




	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
disclosures 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 this action 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 connection with our review of
your
filing or in response to our comments on your filing.

        Any questions regarding the above should be directed to me
at
(202) 942-1809, or in my absence to Robert Benton at (202) 942-
1811.

							Sincerely,



							Robert Burnett
						            Staff Accountant


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