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
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Mr. Douglas S. Ramsdale
Home Products International, Inc.
August 23, 2005
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE