MAIL STOP 3561

      August 4, 2005


Mr. W. Edward Clingman, Jr.
Principal
Clingman & Hanger Management Associates, LLC
11038 Lakeridge Parkway, Suite 4
Ashland, VA  23005

      Re:	Fruit of the Loom Unsecured Creditors Trust
      Form 10-K
      Filed July 29, 2005
      File No. File 001-08941

Dear Mr. Clingman:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document 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
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.
General

1. We note you have provided unaudited financial statements that
have
been prepared on an other comprehensive basis of accounting (i.e.
not
prepared in accordance with GAAP).  Please tell us why you have
not
reported financial statements prepared in accordance with GAAP and
why you believe this presentation (i.e. cash basis) is appropriate
in
filings made with the Commission.  In addition, tell us why your
financial statements are not audited in accordance with Article 3
of
Regulation S-X.  We ask that you cite any authoritative guidance
you
may be relying upon in support of your financial statement
presentation.  Please advise or revise to present financial
statements consistent with GAAP and Article 3 of Regulation S-X.

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

      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
disclosure 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 staff comments 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 our review of your filing or in
response to our comments on your filing.

      You may contact Brian K. Bhandari, Staff Accountant, at
(202)
551-3390 or Hugh West, Branch Chief, at (202) 551-3872 if you have
questions regarding comments on the financial statements and
related
matters.

						Sincerely,


						Tia Jenkins
						Senior Assistant Chief Accountant
						Office of Emerging Growth Companies
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W. Edward Clingman, Jr.
Fruit of the Loom Unsecured Creditors Trust
August 4, 2005
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