AMES TRUE TEMPER, INC. 465 Railroad Avenue Camp Hill, Pennsylvania 17011 October 19, 2004 VIA EDGAR - --------- Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Nicholas Panos S. Richard Lee Re: Ames True Temper, Inc. Registration Statement No. 333-118086 ------------------------------------------------------------ Dear Messrs. Panos and Lee: Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, the undersigned hereby respectfully requests that the effective date for the above-referenced Registration Statement on Form S-4 be accelerated so that it will be declared effective at 4:30 p.m. on October 21, 2004, or as soon as practicable thereafter. Please notify Elisabeth Neuberg of Schulte Roth & Zabel LLP, counsel to the undersigned, at (212) 756-2140 as soon as possible as to the time the Registration Statement has been declared effective pursuant to this acceleration request. AMES TRUE TEMPER, INC. By: /s/ Judy Schuchart ----------------------------------- Name: Judy Schuchart Title: Executive Vice President and Chief Financial Officer
