September 22, 2005 via U.S. mail and facsimile Douglas S. Ramsdale, Chief Executive Officer Home Products International, Inc. 4501 West 47th Street Chicago, IL 60632 	Re:	Form 10-K/A for the Fiscal Year Ended January 1, 2005 		Form 10-Q/A for the Fiscal Quarter Ended April 2, 2005 	Filed:	September 16, 2005 	File No.	333-25871 Dear Mr. Ramsdale: We have reviewed your amended Forms 10-K/A and 10-Q/A filed on September 16, 2005 and have the following additional comment. If you disagree, we will consider your explanation as to why our comment is inapplicable. 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. We reviewed your Form 10-K/A for the fiscal year ended January 1, 2005 and Form 10-Q/A for the fiscal quarter ended April 2, 2005. Based on your disclosures related to the lease accounting and Mexican subsidiary adjustments, it appears as though these adjustments in aggregate had a material impact to your loss before income taxes, net loss, and loss per common share for the fiscal year ended January 1, 2005. Please tell us what consideration you gave to this and any additional factors you considered in concluding that the restatements related to lease accounting and Mexican subsidiary adjustments did not constitute a material weakness. * * * * As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments. If you have any questions regarding these comments, please direct them to Meagan Caldwell, Staff Accountant, at (202) 551- 3754 or, in her absence, to the undersigned at (202) 551-3768. 							Sincerely, 							John Cash 							Accounting Branch Chief ?? ?? ?? ?? Mr. Douglas S. Ramsdale Home Products International, Inc. August 23, 2005 Page 1 of 2 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE