Goldman, Sachs & co. | 85 Broad Street | New York, New York 10004 Tel: 212-902-1000 Goldman Sachs Logo] March 21, 2006 Securities and Exchange commission 100 Fifth Street, N.W. Washington, D.C. 20549 Re: Tim Hortons Inc. Form S-1 Registration No. 333-130035 Ladies and Gentlemen: In connection with the above-captioned Registration Statement, we wish to advise that between March 13, 2006, and the date hereof, 16,498 copies of the Preliminary Prospectus dated March 13, 2006 were distributed as follows: 13,531 to 15 prospective underwriters; 2,503 to 2,503 institutional investors; 0 to 0 prospective dealers; 32 to 7 individuals; 9 to 3 rating agencies and 423 to 7 others. We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934. We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statements, as amended, be accelerated to 3 pm on March 21, 2006 or as soon as thereafter practicable. Very truly yours, GOLDMAN, SACHS & CO. RBC CAPITAL MARKETS CORPORATION As Representatives of the Prospective Underwriters By: Goldman, Sachs & Co. ---------------------- (Goldman, Sachs & Co.)