KAHIKI FOODS, INC.
1100 MORRISON ROAD
GAHANNA, OH 43230
Phone: 614.322.3180
Fax: 614.322.3199


August 30, 2006

Mr. Karl Hiller
Branch Chief
Securities and Exchange Commission
100 F Street, N.E., Mail Stop 7010
Washington, DC 20549-7010

RE: Kahiki Foods, Inc.
       File No. 333-113925
       Your comment letters of April 14, 2006 and August 15, 2006


Dear Mr. Hiller:

Thank you for your April 14, 2006 letter of comments on two amended filings made
by Kahiki Foods, Inc. ("Kahiki"). The comments related to Kahiki's Amendment
Number 1 to Form 10-KSB for the fiscal year ended March 31, 2005, and to
Kahiki's Amendment Number 1 to Form 10-QSB for the fiscal quarter ended December
31, 2005. Thank you also for your August 15, 2006 letter of comments on Kahiki's
filing on Form 10-KSB for the fiscal year ended March 31, 2006.

This letter is in response to both of your comment letters.

As requested in comment 1 of the August 15 letter, we filed our response letter
dated July 14, 2006 on EDGAR. This letter will also be filed on EDGAR.

After discussion of this letter with Tracie Towner of your staff, we will file
four amended filings to include the changes outlined herein. We will file an
amended 10-KSB for March 31, 2005, an amended 10-KSB for March 31, 2006, an
amended 10-QSB for December 31, 2005, and an amended 10-QSB for June 30, 2006.
As the revised disclosures do not affect net income and are corrected in the
2006 filings, we question the materiality of filing amendments to the 2005
filings. If it were possible to avoid filing the March 2005 and the December
2005 amendments noted above, we would appreciate it. We will be filing the March
2006 and June 2006 amended filings, and thus the public would have current
information including these changes.

Our response below is somewhat more involved than a simple response to your
comments, as we found that additional disclosures were necessary for the 2005
reports. I enclose below the proposed commentary from the explanatory notes for
each amended report, with supplemental notes [in brackets] referring them to
sections of your comment letters. We will not include the bracketed information
in the final amended filings.

At Ms. Towner's request, we confirm that on October 19, 2004, our registration
statement on Form SB-2 (Commission file number 333-113925) became effective. The
registration statement registered 100,000 of our common shares for sale by a
shareholder of Kahiki. The offering terminated by the




shareholder before any common shares were sold. [This is in response to your
comment number 3 in the April 14 letter.]

All amended filings will have the word "restated" on columnar data, including
the balance sheets, the income statements, and the cash flow statements, as well
as tabular data in the footnotes. [This is in response to comment number 2 in
the August 15 letter.]

We analyzed EITF 01-9. We determined that credits that we gave for freight
should have been shown as reductions of net sales instead of as part of cost of
sales. Such freight credits apply solely to the products on the invoice on which
the freight credit appears. They do not apply to prior or future sales. The
freight credits are related case by case to the products on the invoice, and are
not separable from that sale. All amended filings will have restatements to
reduce both sales and cost of sales for the effects of this. However, due to the
time necessary to determine the freight credits and to restate, we will not be
able to file the restated financials within the time limit requested in your
August 15 letter. [This is in response to your comment number 3 in the August 15
letter.] We expect to have the restated forms available at the end of next week.
[This is in response to your closing comments in your August 15 letter.]



FORM 10-KSB FOR FISCAL YEAR ENDED MARCH 31, 2005:

EXPLANATORY NOTE TO AMENDED AND RESTATED FORM 10-KSB [The words "AMENDED AND
RESTATED" are in response to your comment 2 in the August 15 letter.]

On June 21, 2005, KAHIKI FOODS, INC. ("Kahiki" or "we") filed its Annual Report
on Form 10-KSB for its fiscal year ended March 31, 2005. On March 30, 2006,
Kahiki filed Amendment Number 1 to its Annual Report on Form 10-KSB for its
fiscal year ended March 31, 2005 ("Amendment Number 1") to restate certain
information. This filing is Amendment Number 2 to Kahiki's Annual Report on Form
10-KSB for its fiscal year ended March 31, 2005 ("this Amendment"). We believe
this Amendment is necessary to modify and restate the report to comply with
generally accepted accounting principles in the United States and Kahiki's
filing obligations under the Exchange Act. [The prior sentence is the response
to your comment number 1 in the April 14 letter.] In this Amendment, we amended
and restated certain amounts and disclosures in the accompanying balance sheets,
statements of cash flows, in sales and cost of sales (but not net income) on the
income statements, and in footnotes to the financial statements. We also amended
the Management's Discussion And Analysis Or Plan Of Operation to include
additional information. We inserted the word "restated" above tabular
information that has been restated. [This is in response to your comment number
2 in the April 14 letter and the same comment number in the August 15 letter.]
The events in this amended report are as of the initial filing date of June 21,
2005, and do not include subsequent events. This Amendment does not modify the
disclosures in the original filing other than as described in this explanatory
note. Other than the incorporation by reference of certain exhibits to the
original and amended filings, we have included the entire amended Form 10-KSB in
this filing for the reader's convenience. This Amendment number 2 is being filed
to amend and restate the following items:




1. We amended the reference on the title page under "DOCUMENTS INCORPORATED BY
REFERENCE" to identify that we incorporated documents by reference into Part III
instead of into Part II as initially filed.

2. We amended the discussion in ITEM 1: "DESCRIPTION OF BUSINESS - OVERVIEW" to
state that no other customer accounted for more than 10% of our sales in fiscal
2005 or 2004.

3. We amended the discussion in ITEM 6: "MANAGEMENT'S DISCUSSION AND ANALYSIS OR
PLAN OF OPERATION - DISCUSSION OF SIGNIFICANT ACCOUNTING POLICIES" to include
discussion of: USE OF ESTIMATES; ACCOUNTS RECEIVABLE - TRADE; CUSTOMER
INCENTIVES; IMPAIRMENT OF ASSETS WITH LONG LIVES; and INTEREST RATE SWAP. This
represents only a correction in disclosure and not a change in policy.

4. We amended the discussion in ITEM 6: "MANAGEMENT'S DISCUSSION AND ANALYSIS OR
PLAN OF OPERATION - LIQUIDITY AND CAPITAL RESOURCES" to include discussion of a
letter of credit agreement, and guarantees of some of Kahiki's debt by two of
its officers. These are all corrections in disclosure.

5. We include herein an amended Report of Independent Registered Public
Accounting Firm on the audit of the financial statements for the fiscal year
ended March 31, 2005. [This is in response to your comment number 3 in the April
14 letter.]

6. We include herein an amended Report of Independent Registered Public
Accounting Firm on the audit of the financial statements for the fiscal year
ended March 31, 2004. [This is in response to your comment number 3 in the April
14 letter.]

7. We incorporated by reference to the original filing exhibit 14.1 - Code of
ethics. We incorporated by reference to Amendment Number 1 exhibit 10.9
Subordinated Promissory Note to Alice Tsao dated August 19, 2003.

8. We filed as new exhibits the following documents:

 Exhibit 10.11 - Registration Rights Agreement between Registrant and Barron
Partners LP, dated February 27, 2004;

 Exhibit 10.12 - Promissory Note of Registrant to KeyBank National Association
dated June 1, 2004 (revolver);

 Exhibit 10.13 - Business Loan Agreement (Asset Based) between Registrant and
KeyBank National Association dated June 1, 2004 (revolver);

 Exhibit 10.14 - Addendum to Business Loan Agreement (Asset Based) between
Registrant and KeyBank National Association dated June 1, 2004 (revolver);

 Exhibit 31.1 - Certification of the Chief Executive Officer Pursuant to Section
302 of the Sarbanes-Oxley Act of 2002; [This is in response to your comment
number 4 in the April 14 letter.]

 Exhibit 31.2 - Certification of the Chief Financial Officer Pursuant to Section
302 of the Sarbanes-Oxley Act of 2002; and [This is in response to your comment
number 4 in the April 14 letter.]



 Exhibit 32 - Certification of the Chief Executive Officer and Chief Financial
Officer pursuant to Rule 15d-14(b) and Section 1350 of Chapter 63 of Title 18 of
the United States Code, as adopted pursuant to Section 906 of the Sarbanes-Oxley
Act of 2002. [This is in response to your comment number 4 in the April 14
letter.]

9. We amended and restated the balance sheet as of March 31, 2005 to show a net
cash overdraft at that date as an addition to accounts payable in current
liabilities rather than as a negative asset. Those adjustments also changed
numerous subtotals and totals on the balance sheets, and in the restated
statements of cash flows. This is a change in disclosure.

10. We amended the reported value of machinery and equipment as of March 31,
2005 by $1 to correct for rounding errors. We made similar $1 adjustments to the
values of accounts receivable, machinery and equipment, and other assets as of
March 31, 2004. We made similar $1 rounding adjustments to the values for
purchase of new facility improvements, net cash used in investing activities,
and proceeds from long-term debt, all on the statement of cash flows for the
year ended March 31, 2004. This is a change in disclosure.

11. We reclassified the $150,000 value of a note payable to a related party from
"Current debt" to "Related Party Note Payable" on the balance sheet at March 31,
2004. This is a change in disclosure.

12. We corrected and restated disclosure of new borrowings of debt and of
payments of debt in the accompanying statement of cash flows for the year ended
March 31, 2005. There was no change in total cash flows from financing
activities from this correction. This is a change in disclosure.

13. We restated net sales and related cost of sales by $XXXXXXX and $XXXXXXX for
the years ended March 31, 2005 and 2004, respectively, to reflect invoiced
freight discounts to customers as a reduction in sales rather than as freight
costs included as part of cost of sales. The freight discounts are more properly
shown as a reduction in revenue per the conclusions reached in Emerging Issues
Task Force Issue No. 01-9. This represents a correction in policy as well as a
correction in disclosure. [This is in response to comment 3 in the August 15
letter.]

14. We include herein as footnote 13 to the accompanying financial statements a
summary of the error corrections and restatements identified in paragraphs 9,
10, 11, 12, and 13 above. [This paragraph is in response to your comment number
2 in the April 14 letter and to your comment number 2 in the August 15 letter.]

15. We amended the description of our revenue recognition accounting policy
included in footnote 2 to the accompanying financial statements. This represents
only a correction in disclosure and not a change in policy.
[This is in response to your comment number 5 in the April 14 letter.]

16. We added a description of our freight credits accounting policy to footnote
2 to the accompanying financial statements. This represents a correction in
disclosure and a change in policy. [This is in response to your comment number 6
in the April 14 letter and to comment 3 in the August 15 letter.]




17. We added a description of our accounting policy on impairment of assets with
long lives to footnote 2 to the accompanying financial statements. This
represents only a correction in disclosure and not a change in policy.

18. We added a description of our accounting policy on our interest rate swap to
footnote 2 to the accompanying financial statements. This represents only a
correction in disclosure and not a change in policy.

19. We added a fuller description of our letter of credit agreement to footnote
2 to the accompanying financial statements. This represents only a correction in
disclosure and not a change in policy.

20. We added a description of our accounting policy for income taxes to footnote
2 to the accompanying financial statements. This represents only a correction in
disclosure and not a change in policy.

21. We amended the disclosure of income taxes in footnote 7 to the accompanying
financial statements to provide further disclosures required by generally
accepted accounting principles in the United States. This represents a
correction in disclosure.

22. We amended the disclosures of Stockholders' Equity and Stock Options in
footnote 8 to the accompanying financial statements to provide further
disclosures required by generally accepted accounting principles in the United
States. The increased disclosures included: common shares reserved for issuance
on potential exercise of warrants, options, and preferred stock; the
convertibility of certain debt to preferred stock; the requirement for
shareholders to approve a new issue of preferred stock; the existence of
warrants to purchase common stock; and Kahiki's contractual requirements to
register shares of stock. We also amended the disclosures of stock options to
correct errors in quantities and to separate disclosures of options issued under
our stock option plan and those which were not issued under the stock option
plan. All of these represent corrections in disclosure.

23. We amended the disclosures in footnote 10 to the accompanying financial
statements to provide names and percentages of customers that accounted for more
than 10% of our sales in fiscal 2005 and 2004, and to state that no other
customer accounted for more than 10% of our sales in fiscal 2005 or 2004. This
represents a correction in disclosure. [This is in response to your comment
number 7 in the April 14 letter.]

24. We added to footnote 12 to the accompanying financial statements disclosure
of guarantees of Kahiki's debt by related parties. We expanded the discussion in
the same footnote of the poultry purchase and the co-pack agreements with a
related party. This represents a correction in disclosure.



FORM 10-QSB FOR FISCAL QUARTER ENDED DECEMBER 31, 2005:

EXPLANATORY NOTE TO AMENDED AND RESTATED FORM 10-QSB

On February 14, 2006, KAHIKI FOODS, INC. ("Kahiki" or "we") filed its Quarterly
Report on Form 10-QSB for its fiscal quarter ended December 31, 2005. On March
30, 2006, Kahiki filed Amendment Number 1 to its Quarterly Report on Form 10-QSB
for its fiscal quarter ended December 31, 2005 ("Amendment Number 1") to restate
certain information. This filing is




Amendment Number 2 to Kahiki's Quarterly Report on Form 10-QSB for its fiscal
quarter ended December 31, 2005 ("this Amendment"). We believe this Amendment is
necessary to modify and restate the report to comply with generally accepted
accounting principles in the United States and Kahiki's filing obligations under
the Exchange Act. [The prior sentence is in response to your comment numbers 1
and 8 in the April 14 letter.] In this Amendment, we amended and restated
certain amounts and disclosures in the accompanying balance sheets, statements
of cash flows, in sales and cost of sales (but not net income) on the income
statements, and in footnotes to the financial statements. We also amended the
Management's Discussion And Analysis Or Plan Of Operation to include additional
information. We inserted the word "restated" above tabular information that has
been restated. [This is in response to your comment number 2 in the April 14
letter and the same comment number in the August 15 letter.] The events in this
Amendment are as of the initial filing date of February 14, 2006, and do not
include subsequent events. This Amendment does not modify the disclosures in the
original filing other than as described in this explanatory note. We have
included the entire amended Form 10-QSB in this filing for the reader's
convenience. This 10-QSB/A (Amendment number 2) is being filed to amend and
restate the following items:

1. In Amendment Number 1, we amended and restated the balance sheet as of March
31, 2005 to show a net cash overdraft at that date as an addition to accounts
payable in current liabilities rather than as a negative asset. Those
adjustments also changed numerous subtotals and totals on the balance sheet, and
in the restated statement of cash flows. This is a change in disclosure.

2. In Amendment Number 1, we amended the reported value of machinery and
equipment as of March 31, 2005 by $1 to correct for rounding errors. This is a
change in disclosure.

3. In this Amendment, we amended and restated the balance sheet as of December
31, 2005 to show debt which had technical defaults at that date as current
liabilities and not as long-term debt. This is a change in disclosure.

4. In Amendment Number 1, we increased net sales and cost of sales by $123,000
for the three- and nine- month periods ended December 31, 2005 to reflect
invoiced freight discounts to a customer which were originally subtracted from
reported net sales. That was in error. In this Amendment, we restated net sales
and related cost of sales by $123,000 and $XXXXXXX for the three- month periods
ended December 31, 2005 and 2004, and by $XXXXXXX and $XXXXXXX for the
nine-month periods ended December 31, 2005 and 2004, all respectively, to
reflect invoiced freight discounts to customers as a reduction in sales rather
than as freight costs included as part of cost of sales. The freight discounts
are more properly shown as a reduction in revenue per the conclusions reached in
Emerging Issues Task Force Issue No. 01-9. This represents a correction in
policy as well as a correction in disclosure. [This is in response to comment 3
in the August 15 letter.]

5. In this Amendment, we corrected and restated disclosure of new borrowings of
debt and of payments of debt in the accompanying statement of cash flows for the
nine months ended December 31, 2004. There was no change in total cash flows
from financing activities from this correction. This is a change in disclosure.




6. We include herein as footnote 13 to the accompanying unaudited financial
statements a summary of the error corrections and restatements identified in
paragraphs 1, 2, 3, 4, and 5 above. [This is in response to your comment numbers
2 and 8 in the April 14 letter and to your comment number 2 in the August 15
letter.]

7. We amended the description of our revenue recognition accounting policy
included in footnote 2 to the accompanying unaudited financial statements. This
represents only a correction in disclosure and not a change in policy. [This is
in response to your comment numbers 5 and 8 in the April 14 letter.]

8. We added a description of our freight credits accounting policy to footnote 2
to the accompanying unaudited financial statements. This represents a correction
in disclosure and a change in policy. [This is in response to your comment
numbers 6 and 8 in the April 14 letter and to comment 3 in the August 15
letter.]

9. We added a description of our accounting policy on impairment of assets with
long lives to footnote 2 to the accompanying unaudited financial statements.
This represents only a correction in disclosure and not a change in policy.

10. We added a description of our accounting policy on our interest rate swap to
footnote 2 to the accompanying unaudited financial statements. This represents
only a correction in disclosure and not a change in policy.

11. We added to footnote 10 to the accompanying unaudited financials statements
a description of guarantees of some of Kahiki's debt by two of its officers.
This is a change in disclosure.

12. We deleted a sentence from footnote 11 to the accompanying unaudited
financial statements that indicated that Kahiki was in compliance with all debt
covenants at December 31, 2005. This is a change in disclosure.

13. We amended and restated the disclosures of debt in footnote 11 to the
accompanying unaudited financials statements to report and explain the technical
defaults in Kahiki's debt. This is a change in disclosure.

14. We amended and restated the discussion in Item 2: "Management's Discussion
And Analysis Or Plan Of Operations - Liquidity And Capital Resources" to include
discussion of technical defaults in various debt agreements. These technical
defaults existed as of December 31, 2005. We also included discussion of
guarantees of some of Kahiki's debt by two of its officers. These are all
corrections in disclosure.

15. We amended Item 3 Controls and Procedures to provide a better explanation of
the results of our evaluation of disclosure controls and procedures. [This is in
response to your comment number 9 in the April 15 letter.]

16. We filed as new exhibits the following documents:

 Exhibit 31.1 - Certification of the Chief Executive Officer Pursuant to Section
302 of the Sarbanes-Oxley Act of 2002; [This is in response to your comment
numbers 4 and 8 in the April 15 letter.]




 Exhibit 31.2 - Certification of the Chief Financial Officer Pursuant to Section
302 of the Sarbanes-Oxley Act of 2002; and [This is in response to your comment
numbers 4 and 8 in the April 15 letter.]

 Exhibit 32 - Certification of the Chief Executive Officer and Chief Financial
Officer pursuant to Rule 15d-14(b) and Section 1350 of Chapter 63 of Title 18 of
the United States Code, as adopted pursuant to Section 906 of the Sarbanes-Oxley
Act of 2002. [This is in response to your comment numbers 4 and 8 in the April
15 letter.]

17. We added disclosure to Part II, Item 3 Defaults Upon Senior Securities to
include discussion of technical defaults in various debt agreements.




FORM 10-KSB FOR FISCAL YEAR ENDED MARCH 31, 2006:

EXPLANATORY NOTE TO AMENDED AND RESTATED FORM 10-KSB [The words "AMENDED AND
RESTATED" are in response to your comment 2 in the August 15 letter.]

On July 14, 2006, KAHIKI FOODS, INC. ("Kahiki" or "we") filed its Annual Report
on Form 10-KSB for its fiscal year ended March 31, 2006. This filing is
Amendment Number 1 to Kahiki's Annual Report on Form 10-KSB for its fiscal year
ended March 31, 2006 ("this Amendment"). We believe this Amendment is necessary
to modify and restate the report to comply with generally accepted accounting
principles in the United States and Kahiki's filing obligations under the
Exchange Act. [The prior sentence is the response to your comment number 1 in
the April 14 letter.] In this Amendment, we amended and restated certain amounts
and disclosures in the balance sheets, in sales and cost of sales (but not net
income) on the income statements, in the statements of cash flows, and in
footnotes to the financial statements. We also amended the Management's
Discussion And Analysis Or Plan Of Operation to include additional information.
We inserted the word "restated" above tabular information that has been
restated. [This is in response to your comment number 2 in the April 14 letter
and the same comment number in the August 15 letter.] The events in this amended
report are as of the initial filing date of July 14, 2006, and do not include
subsequent events. This Amendment does not modify the disclosures in the
original filing other than as described in this explanatory note. Other than the
incorporation by reference of certain exhibits to the original filing, we have
included the entire amended Form 10-KSB in this filing for the reader's
convenience. This Amendment number 1 is being filed to amend and restate the
following items:

1. We incorporated by reference to the original filing the following exhibits:
 Exhibit 10.10 - Employment Agreement with Alan L. Hoover

 Exhibit 10.11 - Registration Rights Agreement between Registrant and Barron
Partners LP, dated February 27, 2004

 Exhibit 10.12 - Promissory Note of Registrant to KeyBank National Association
dated June 1, 2004 (revolver)

 Exhibit 10.13 - Business Loan Agreement (Asset Based) between Registrant and
KeyBank National Association dated June 1, 2004 (revolver)



 Exhibit 10.14 - Addendum to Business Loan Agreement (Asset Based) between
Registrant and KeyBank National Association dated June 1, 2004 (revolver)

2. We filed as new exhibits the following documents:

 Exhibit 31.1 - Certification of the Chief Executive Officer Pursuant to Section
302 of the Sarbanes-Oxley Act of 2002; [This is in response to your comment
number 4 in the April 14 letter.]

 Exhibit 31.2 - Certification of the Chief Financial Officer Pursuant to Section
302 of the Sarbanes-Oxley Act of 2002; and [This is in response to your comment
number 4 in the April 14 letter.]

 Exhibit 32 - Certification of the Chief Executive Officer and Chief Financial
Officer pursuant to Rule 15d-14(b) and Section 1350 of Chapter 63 of Title 18 of
the United States Code, as adopted pursuant to Section 906 of the Sarbanes-Oxley
Act of 2002. [This is in response to your comment number 4 in the April 14
letter.]

3. We restated net sales and related cost of sales by $XXXXXXX and $XXXXXXX for
the years ended March 31, 2006 and 2005, respectively, to reflect invoiced
freight discounts to customers as a reduction in sales rather than as freight
costs included as part of cost of sales. The freight discounts are more properly
shown as a reduction in revenue per the conclusions reached in Emerging Issues
Task Force Issue No. 01-9. This represents a correction in policy as well as a
correction in disclosure. [This is in response to comment 3 in the August 15
letter.]

4. We amended and restated footnote 18 to the accompanying financial statements
to reflect the error corrections and restatements identified in paragraph 3
above. Note that several other changes in the financial statements for the year
ended March 31, 2005 had already been included in note 18 prior to this
Amendment. [This paragraph is in response to your comment number 2 in the April
14 letter.]

5. We amended the description of our freight credits accounting policy in
footnote 2 to the accompanying financial statements. This represents a
correction in disclosure and a change in policy. [This is in response to your
comment number 6 in the April 14 letter and to comment 3 in the August 15
letter.]

6. We amended the discussion in ITEM 6: "MANAGEMENT'S DISCUSSION AND ANALYSIS OR
PLAN OF OPERATION" to include updates to tabular presentations of percentages
and to amounts shown as sales and cost of sales in the commentary. This
represents a correction in disclosure caused by a change in policy.



FORM 10-QSB FOR FISCAL QUARTER ENDED JUNE 30, 2006:

EXPLANATORY NOTE TO AMENDED AND RESTATED FORM 10-QSB

On August 14, 2006, KAHIKI FOODS, INC. ("Kahiki" or "we") filed its Quarterly
Report on Form 10-QSB for its fiscal quarter ended June 30, 2006. This filing is
Amendment Number 1 to Kahiki's Quarterly Report on Form 10-QSB for its fiscal
quarter ended June 30, 2006 ("this Amendment"). We believe this




Amendment is necessary to modify and restate the report to comply with generally
accepted accounting principles in the United States and Kahiki's filing
obligations under the Exchange Act. [The prior sentence is in response to your
comment numbers 1 and 8 in the April 14 letter.] In this Amendment, we amended
and restated certain amounts and disclosures in the accompanying statements of
cash flows, in sales and cost of sales (but not net income) on the income
statements, and in footnotes to the financial statements. We also amended the
Management's Discussion And Analysis Or Plan Of Operation to include additional
information. We inserted the word "restated" above tabular information that has
been restated. [This is in response to your comment number 2 in the April 14
letter and the same comment number in the August 15 letter.] The events in this
Amendment are as of the initial filing date of August 14, 2006, and do not
include subsequent events. This Amendment does not modify the disclosures in the
original filing other than as described in this explanatory note. We have
included the entire amended Form 10-QSB in this filing for the reader's
convenience. This 10-QSB/A (Amendment number 1) is being filed to amend and
restate the following items:

1. We restated net sales and cost of sales by $XXXXXXX and $XXXXXXX for the
three-month periods ended June 30, 2006 and 2005, respectively, to reflect
invoiced freight discounts to customers as a reduction in sales rather than as
freight costs included as part of cost of sales. The freight discounts are more
properly shown as a reduction in revenue per the conclusions reached in Emerging
Issues Task Force Issue No. 01-9. This represents a correction in policy as well
as a correction in disclosure. [This is in response to comment 3 in the August
15 letter.]

2. We amended and restated footnote 14 to the accompanying unaudited financial
statements to reflect the error corrections and restatements identified in
paragraph 1 above. Note that several other changes in the financial statements
for the year ended March 31, 2005 had already been included in note 14 prior to
this Amendment. [This paragraph is in response to your comment number 2 in the
April 14 letter.]

3. We amended the description of our freight credits accounting policy in
footnote 2 to the accompanying financial statements. This represents a
correction in disclosure and a change in policy. [This is in response to your
comment number 6 in the April 14 letter and to comment 3 in the August 15
letter.]

4. We amended the discussion in ITEM 2: "MANAGEMENT'S DISCUSSION AND ANALYSIS OR
PLAN OF OPERATION" to include updates to tabular presentations of percentages
and to amounts shown as sales and cost of sales in the commentary. This
represents a correction in disclosure caused by a change in policy.

5. We filed as new exhibits the following documents:

 Exhibit 31.1 - Certification of the Chief Executive Officer Pursuant to Section
302 of the Sarbanes-Oxley Act of 2002; [This is in response to your comment
numbers 4 and 8 in the April 15 letter.]

 Exhibit 31.2 - Certification of the Chief Financial Officer Pursuant to Section
302 of the Sarbanes-Oxley Act of 2002; and [This is in response to your comment
numbers 4 and 8 in the April 15 letter.]




Exhibit 32 - Certification of the Chief Executive Officer and Chief Financial
Officer pursuant to Rule 15d-14(b) and Section 1350 of Chapter 63 of Title 18 of
the United States Code, as adopted pursuant to Section 906 of the Sarbanes-Oxley
Act of 2002. [This is in response to your comment numbers 4 and 8 in the April
15 letter.]

* * * * *

We hereby acknowledge that:
* The company is responsible for the adequacy and accuracy of the disclosures in
the filings;
* 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.

Thank you again for your comments. Please call me with any questions. My direct
dial number is 614.322.3189.

Sincerely,


/s/ Frederick A. Niebauer
Frederick A. Niebauer
Chief Financial Officer