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Mail Stop 3561          August 26, 2008  American Vanguard Corporation James A. Barry-Chief Financial Officer 4695 MacArthur Court  Newport Beach, California
Re:  American Vanguard Corporation
 Form 10-K for the year ended December 31, 2007
Filed March 17, 2008
  File Number: 001-13795

Dear Mr. Barry:

We have reviewed your response lett er dated August 8, 2008 and have the
following additional comments.  We think you should revise your future filings in response to these comments.  If you disagree, we will consider your explanation as to why our comments are not applicable or a restatement is unnecessary.  Please be as
detailed as necessary.  We look forward to working with you in these respects and
welcome any questions you may have about any aspects of our review.

Form 10-K for the fiscal year ended December 31, 2007

Item 7 – Management’s Discussion and Analysis
Results of Operations, page 25

1. We note your response to our prior comment 1.  While you confirm that you will
provide more comprehensive disclosure, you state that this disclosure will be
focused on gross profit.  However, in our  prior comment we stated that gross
profit disclosures should be supplemente d with or, preferably, replaced by a
discussion and analysis of co sts on a stand-alone basis (not  in the context of gross
profit).  Therefore, please confirm to us that you will provide a robust discussion
and analysis of costs on a stand-alone basis and please provide us with a copy of
your intended revised disclosure.

James A. Barry-Chief Financial Officer
American Vanguard Corporation
August 26, 2008 Page 2
2. We note your responses to our prior co mments 2, 3, and 5, in which you cite
competitive disadvantage from disclosure of trade secrets as your basis for not
disclosing to your investors information required under GAAP and U.S. securities
laws.  However, paragraphs 109 th rough 111 of SFAS 131 indicate that a
competitive harm exception is inappropria te as it would provide a means for
broad non-compliance with the requirements of the statements a nd that enterprises
are not likely to suffer competitive harm because most competitors have other sources of more detailed information about  an enterprise than  that disclosed in
financial statements. Additionally, paragraph (II)(B)(2) of Staff Legal Bulletin 1 also indicates that only under unusual circumstances  would confidentiality be
provided for disclosures required by Regulation S-K or for information that is
material to investors.  As such, the use of competitive harm for broad non-compliance with disclosure requiremen ts under GAAP and Regulations S-K and
S-X is inappropriate and, would only apply under unusual circumstances.  As such, we reissue our prior comments 2, 3, and 5 in full.

3. We note your response to our prior comment 2.  While you confirm that you will quantify factors that lead to large variances and disclose business reasons for
same, you do not specifically confirm your agreement with the numerous other
changes requested in our prior comment.  In  light of this, we reissue the original
comment in full.

A significant portion of your results of operations disc losure is dedicated to
stating, in narrative text form, dollar and percentage changes in accounts, some of
which is already included in tables.  In  addition, while you discuss certain factors
to which changes are attri butable, you do not quantify a large number of these
factors nor analyze the unde rlying business reasons for the changes.  For example,
you state that your herbicide Impact gr ew substantially in 2007, but you do not
quantify this factor nor an alyze the underlying reason for the change.  We believe
your disclosures could be improved and ma de much more user-friendly and clear
by:
• increasing the use of tables to pres ent dollar and percentage changes in
accounts, rather than including such information in narrative text form;
• using tables to list, quantify, and sum all of the material individual
factors to which changes in accounts are attributable;
• refocusing the narrative text portion of the disclosure on analysis of
the underlying business reasons for the individual factors in the tables
above;
• ensuring that all material factor s are quantified and analyzed; and
• quantifying the effects of change s in both price and volume on
revenues and expense categories, where appropriate.
With regard to refocusing the narrative te xt portion of the disclosure on analysis
of the underlying business reasons for the individual factors, we note that you
provide a more substantive disclosure of th is type of information in your earnings

James A. Barry-Chief Financial Officer
American Vanguard Corporation
August 26, 2008 Page 3
conference calls than in your periodic filings on Forms 10-Q and 10-K.  We believe much of the “color” you provide during those calls would be useful to
investors in understanding th e results of operations di sclosure in your periodic
filings and we believe you should include such analysis of the underlying business reasons for changes in results of operations in future filings.  Please provide us with a copy of your intended revised disclosure.

4. We note your response to our prior comment 3.  You state that s ubstantially all of
your product lines are “off pa tent” and that you acquire mature chemistries from
larger competitors.  We are not clear as to  the relevance of thes e facts to our prior
comment.  While we understand that products  were sold by the competitors from
whom you acquired them prior to the da tes acquired, these pre-acquisition sales
amounts are not recognized in your cons olidated statements of operations.
Therefore, the sale of recently acquired products in a period in which the prior
comparable period included no sales of such  products may be a material factor to
which changes in sales, cost of sales, and other accounts are attributable.  As a
result, this factor should be disclosed, quantified, and analyzed.  Therefore, we
reissue the original comment in full.

To provide investors with an unders tanding of the effects of product line
acquisitions on your growth and results  of operations, please quantify the
aggregate change in revenue and cost of  goods sold related to products not sold
for the full comparable prior period.  Please provide us with a copy of your
intended revised disclosure.
 Liquidity and Capital Resources, page 28

5. Please revise your liquidity and capital resources disclosures to discuss the
underlying factors resulting in changes to  your cash balance, instead of merely
repeating what is shown on the statement of cash flows.  For example, we note a significant decrease in y our accounts receivable balance at December 31, 2007
without disclosure indicating the underlying reasons for th e decrease or its impact
in your operating cash flows.   Furthermore, it appears that you have and will continue to expand your business through acquisitions.  In this regard, your
disclosures should be expanded to address the impact of these acquisitions on your cash flows and operating results.  Additionally, your disclosures should provide further details regarding your  overall capital structure, including a
discussion of material debt covenants and a more detailed discussion of your total
outstanding long-term debt, borrowing capacity and interest costs.  Please provide
us with a copy of your in tended revised disclosure.

James A. Barry-Chief Financial Officer
American Vanguard Corporation
August 26, 2008 Page 4  Item 8- Financial Statements and Supplementary Data

 Notes to the Financial Statements

 (4) Litigation and Environmental, page 76

6. We note your response to our prior comment 8.  You cite attorney-client privilege
and the attorney work product doctrine as your bases for not disclosing with
specificity any accrued loss contingency to your investors, as required under
GAAP and U.S. securities laws.  We do not  agree with your conclusion that these
bases alleviate your disclosure obligati ons.  To the extent you continue to
disagree, please confirm to us the specific agreement of the na tional office of your
independent auditors with your conclusi ons and provide us with the name and
telephone number of the national office representative providing concurrence.

You also state that you do not presently belie ve that it is appropriate to accrue loss
contingency reserves for any litigation matter reported in your filing, because you
do not believe that a loss is both probable  and reasonably estimable in any case.
In those circumstances, we agree that accrual is not required.  You should,
however, ensure that your disclosures ar e clear about your conclusions regarding
each matter.  Given that loss contingencies are not required to be disclosed if the
likelihood of loss is remote, the fact that contingencies are disc losed implies that
you believe the likelihood of loss is at least reasonably possible.  However, your current disclosures do not always make clear whether your conclusion as to the
likelihood of loss is reasonably possible or probable.  Therefore, you should
explicitly state your conclusion for each matter disclosed.  In addition, for matters
where you judge the likelihood of loss to be reasonably possible or probable but for which you believe the amount of loss cannot be reasonably estimated, you should explicitly state your conclusi on that the loss cannot be reasonably
estimated.  We caution, however, that FIN 14 states that accrual of a probable loss
should not be delayed until only a single amount can be reasonably estimated.  When a loss is probable and the reasonable estimate of the loss is a range, the best
estimate within the range should be accr ued.  If no amount within the range
appears to be a better estimate than  any other amount within the range, the
minimum amount in the range should be accrued.  Where losses are accrued and arose from a range, you should disclose whether the accrual was the best estimate within a range or the low end of the range and the range of reasonably possible losses.  Based on your partial agreement w ith our original comment, we reissue it
in part.  Refer to SFAS 5 and FIN 14 for guidance.

James A. Barry-Chief Financial Officer
American Vanguard Corporation
August 26, 2008 Page 5
Based on your disclosures, it appears that you are subject to si gnificant litigation.
Accordingly, we strongly encourage you to consider adding the following
disclosure in a tabular format:
• Opening loss contingency amounts,
• Increases due to loss contingenc ies recognized du ring the period,
• Increases from changes in estimates of the amounts of loss
contingencies previously recognized,
• Decreases from changes in estimates of amounts of loss contingencies previously recognized or from derecognition of loss contingencies that
are no longer probable,
• Decreases for derecognition of lo ss contingencies settled, and
• Closing loss contingency amounts.
  Please provide us with a copy of  your intended revised disclosure.

* * * * *

 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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

James A. Barry-Chief Financial Officer
American Vanguard Corporation August 26, 2008 Page 6
You may contact Juan Mi gone at (202) 551-3312 or Lyn Shenk, at (202) 551-
3380 if you have questions regarding comments on the financial statements and related
matters.  Please contact the undersigned at (202) 551-3211 with any other questions.

Sincerely,

 David R. Humphrey Branch Chief