SecProbe.io

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<TYPE>CORRESP
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                           AMERICAN LOCKER GROUP INCORPORATED
                                 815 SOUTH MAIN STREET
                                 GRAPEVINE, TEXAS 76051

October 12, 2005

United States Securities and Exchange Commission
Washington, D.C. 20549-7010
Attention:  Ryan Rohn, Staff Accountant

         RE:      American Locker Group Incorporated
                  File #000-00439

Dear Mr. Rohn:

This  correspondence  is in response to your letter  dated  September  12, 2005,
concerning additional information regarding American Locker Group Incorporated's
recent filings.

Question #1. "Provide us with any letter or written communication to
             and from the former accountants regarding the material
             weaknesses in internal control over financial reporting, to
             management or the Audit Committee."

Response:

Enclosed, as supplemental  information,  please find copies of communications by
the Company's independent registered public accounting firm, as follows:

        o  Required Communications related to the audit of the Company  for the
           year ended December  31, 2004,  addressed to the Audit  Committee of
           the Board of Directors of American Locker Group Incorporated,  dated
           June 15, 2005.

        o  Management  Letter  related  to  the audit of the  Company  for the
           year ended December 31, 2004, addressed to the Audit Committee of the
           Board of Directors of American Locker Group Incorporated, and  dated
           May 11, 2005.

Enclosed, as supplemental information, you will also find management's responses
to the  Management  Letter,  dated July 13,  2005.  In the  response,  which was
addressed to the Audit Committee Chairman,  Mr. Stuart Goodner was identified as
a newly hired Senior  Accounting  Manager and future CFO. In September 2005, Mr.
Goodner's employment with the Company was terminated and the search for a CFO is
currently  underway.

Following the completion of your review,  we respectfully  request the return of
the enclosed letters.

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United State Security and Exchange Commission
October 12, 2005
Page 2

Question #2. "Please provide us with a schedule of your fiscal year end
              2004 fourth quarter adjustments to close the books, or
              adjustments recorded in connection with or as a result of the
              audit. Clearly explain the reason for each adjustment. For
              each adjustment, show us the impact on pre-tax net loss.
              Quantify the net effect of all adjustments on pre-tax net
              income (loss). Also, tell us why none of the adjustments
              relate to prior period. Explain in detail why you believe the
              timing of each adjustment is appropriate. Provide a similar
              schedule for the March 2005 and June 2005 quarters."

Response:

Fourth Quarter of 2004
----------------------

During the monthly  closing  process the Company makes a  significant  number of
journal entries to record transactions related to that specific month. These are
considered normal and recurring  monthly closing entries.  The following entries
were  recorded in the fourth  quarter of 2004.  These entries were the result of
additional  year-end  analyses,   annual  accounting  procedures  (eg.  physical
inventory  adjustments,  update of standard costs,  etc.) and entries identified
during the audit process.

<TABLE>
<CAPTION>
<S>                                                                                         <C>
                                                                                           (Increase)
                                                                                            Decrease
                                                                                         Pre-tax (Loss)
                                                                                      ---------------------
1.  Inventory book-to-physical and costing adjustments

       o  The Company's  divisions and  subsidiaries  annually      perform a
          physical  inventory  on October  31st.  At this time,  inventory  cost
          standards  are  updated  to   approximate   recent   acquisition   and
          manufacturing  costs.  In November of 2004,  a number of entries  were
          made to adjust inventory values as a result of the physical  inventory
          and  re-standardization.  The  aggregate  impact of these  adjustments
          decreased  the  pre-tax  loss for the fourth  quarter by  $540,000.  $
                                                                                               540,000

       o  After   analysis,    it   was    determined    that  the    Company's
          accounting  practices during 2004 had improperly accounted for certain
          labor costs.  This discovery caused the Company to quantify the impact
          of the error on the operating  results of the first,  second and third
          quarters of 2004. In addition,  due to cost increases  during 2004, it
          was   determined   that   a   certain   portion   of  the   year   end

<PAGE>

United State Security and Exchange Commission
October 12, 2005
Page 3

          re-standardization  adjustment related to the first,  second and third
          quarters of 2004.  The Form 10-Q's filed for the first three  quarters
          of 2004 were amended to properly  reflect  inventory and cost of sales
          during these  quarters,  and refiled with the SEC in July 2005.  These
          adjustments  served to increase the reported pre-tax income during the
          first three quarters of 2004 by $582,000.
                                                                                              (582,000)
                                                                                      ---------------------

     The  impact  of the  fourth  quarter  of  2004  book-to-physical  inventory
     adjustments  and adjustments to inventory cost, less the restatement of the
     first three  quarters  resulted in a $42,000 net  increase to the  reported
     pre-tax    loss   in   the   fourth    quarter   of   2005.                          $   (42,000)
                                                                                      =====================

2.   Certain of the  Company's  inventories  are  maintained  on the last-in,
     first-out (LIFO) costing method. The calculation  required to determine the
     cost of inventory under the LIFO method was performed in December 2004. The
     adjustment  to properly  reflect  LIFO  costing was  recorded in the fourth
     quarter of 2004,  and  resulted in an increase in the fourth  quarter  2004
     pre-tax loss of $203,000.                                                             $ (203,000)

3.   Inventory valuation reserve adjustments:

       o    The Company made a detailed  evaluation  of its inventory on hand
            at  December  31,  2004.  As a result of this  analysis,  certain
            inventories   deemed  worthless  were  charged-off   directly  to
            earnings. The net impact of these adjustments, made in the fourth
            quarter of 2004,  increased  the fourth  quarter  pre-tax loss by
            $80,000.                                                                        $ (80,000)

<PAGE>

United State Security and Exchange Commission
October 12, 2005
Page 4

       o  The Company's auditors performed  an independent  evaluation of   the
          Company's  on-hand  inventory.  This  analysis  resulted  in  proposed
          journal entries to: 1) reduce a previously  established "lower of cost
          or market" valuation reserve by $194,000;  and 2) increase the reserve
          for potentially obsolete inventory by $124,000. Management agreed with
          the  auditors'  analysis and recorded  the proposed  entries.  The net
          impact of these two entries  service to reduce the fourth quarter loss
          by $70,000.                                                                           70,000
                                                                                      ---------------------

     Net  impact of the  inventory  valuation  reserve  adjustments  made in the
     fourth quarter of 2004. $ (10,000) =====================

4.   With  respect  to  certain  ongoing   environmental   claims,   settlement
     discussions  commenced in the fourth quarter of 2004 and concluded in early
     2005. In previous filings, the potential exposure to an environmental claim
     was  disclosed,  but  because a range of loss could not be  determined,  an
     accrual was not established. As a result of the settlement, the loss became
     estimable  prior to closing the books for December  2004.  Accordingly,  an
     accrual and related  pre-tax  charge to earnings was recorded in the fourth
     quarter of 2004, totaling $1,103,000.                                                $ (1,103,000)

5.   In the fourth quarter of 2004, pursuant to  an analysis by  management,  it
     was determined that collection of certain aged trade receivables had become
     doubtful.  Accordingly,  an entry to  increase  the  reserve  for  doubtful
     accounts  was  posted  totaling  $66,000.  This  adjustment  increased  the
     reported fourth quarter pre-tax loss by $66,000.                                        $ (66,000)

6.   As disclosed in the Company's annual report, the  Company  provides  "Other
     Postretirement  Benefits"  in  the  form  of a  death  benefit  to  certain
     retirees. In 2004, as a result of the aging population of the participants,
     the calculated  liability  under this plan  decreased.  This adjustment was
     proposed by the  Company's  auditors as part of their  audit  findings.  An
     adjustment was posted  decreasing  the reported  pre-tax loss in the fourth
     quarter by $39,000.                                                                       $ 39,000

<PAGE>

United State Security and Exchange Commission
October 12, 2005
Page 5

7.   During the course of their  audit,  the  Company's  auditors  identified an
     error in the accrued payroll calculation at certain divisions/subsidiaries.
     The  auditors  proposed an  adjustment.  Management  agreed and recorded an
     adjustment  that  increased the fourth quarter  pre-tax loss by $32,000.            $     (32,000)

8.   During the  course  of  the  year  the Company provides a monthly estimated
     provision to record expense  associated  with its defined  benefit  pension
     plan.  This  estimated  provision is based on  information  provided to the
     Company  by its  consulting  actuary  at the  beginning  of the  year.  The
     Company's actuary updates the annual pension cost along with the other FASB
     Statement  No.  87  disclosures  at  the  end of the  accounting  year.  An
     adjustment  was made in  December  2004 to  adjust  the  estimated  defined
     benefit pension  expense to the actuary's final  calculation for 2004. This
     adjustment increased the reported fourth quarter pre-tax loss by $20,000.           $     (20,000)

9.   The Company periodically pays year-end discretionary  bonuses  to  both its
     hourly and  salaried  workforce.  During the year,  the Company  accrues an
     estimate  of these  potential  bonuses.  In  December,  after  the Board of
     Directors' approval,  final bonuses were determined and were either paid or
     accrued.  Actual bonuses paid and accrued (i.e., expensed) in excess of the
     accrual  established  for these bonuses  during the year totaled  $198,000.
     Accordingly,  bonuses  in  excess  of the  normal  provision,  recorded  in
     December of 2004,  increased the fourth quarter pre-tax loss by $198,000.          $     (198,000)

10.  Upon performing the bank reconciliation  procedures at  December  31, 2004,
     certain  adjustments  were  identified  and made in  December  2004.  These
     adjustments increased the fourth quarter loss by $14,000.                               $ (14,000)

The  following  entries were  recorded  during the first and second  quarters of
2005.  They  would not be  considered  normal  monthly  closing  entries  in the
ordinary course of business.

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United State Security and Exchange Commission
October 12, 2005
Page 6

First Quarter of 2005
---------------------

1.   During the first quarter of 2005, it became clear that a more   significant
     allocation of the Company's  production  would be shifting to the Company's
     Texas facility.  Accordingly,  management  evaluated its inventory  costing
     model used in Texas to value its work-in-progress inventory. As a result of
     this  evaluation,  a decision was made to adjust the costing  model to more
     accurately account for production labor allocated to work-in-progress.  The
     imprecision  of the prior  costing  model has not been  significant  to the
     Company's  previously  reported  financial  results or financial  position.
     However,  the impact of this change in the costing model will likely become
     significant  to  the  Company's  future  financial  results  and  financial
     position as  production  volumes  continue to shift to Texas.  Accordingly,
     management implemented the costing model in the first quarter of 2005. This
     costing  adjustment  decreased  the  reported  pre-tax  loss for the  first
     quarter of 2005 by $250,000.                                                       $        250,000

2.   On February 8, 2005, the Company was contacted by the United  States Postal
     Service (USPS) and informed that its supply  contract to the USPS would not
     be renewed.  As discussed in more detail within Note 7 of the Form 10-Q for
     the  quarter  ended  March  31,  2005,  the  loss of this  contract  caused
     management  to conclude that the fair value of the Company was no longer in
     excess of the carrying value of the net underlying assets. Accordingly, the
     Company's test for impairment indicated no goodwill exists. As a result the
     Company  recorded an  impairment  charge of $6,155,000 in the quarter ended
     March 31, 2005.                                                                  $       (6,155,000)

3.   Again, as a result  of the  loss of  the USPS  contract, management made an
     evaluation  of  inventories  on hand and  purchase  commitments  related to
     supplying  products under the USPS contract.  As a result of this analysis,
     an entry was made to reserve for the potential that certain inventory items
     are  obsolete  without  the USPS  contract  $147,000.  Further,  management
     identified  certain  committed  purchases  related  to  the  USPS  contract
     totaling $125,000.  The impact of the adjustments for these items increased
     the reported pre-tax loss for the first quarter of 2005 by $272,000.            $          (272,000)

<PAGE>

United State Security and Exchange Commission
October 12, 2005
Page 7

Second Quarter of 2005
----------------------

1.   Because of  decreasing  inventory  quantities  during the second quarter of
     2005 related to the loss of the USPS contract,  management  made a mid-year
     analysis of its LIFO costing.  As a result of the interim  analysis of LIFO
     costing,  an  adjustment  was made to decrease the  previously  established
     debit balance LIFO reserve, thus increasing the pre-tax loss for the second
     quarter of 2005 by $83,000. $ (83,000)

2.   As discussed in greater detail in the Form 10-Q for the quarter  ended June
     30, 2005,  on May 18, 2005,  the Company's  Board of Directors  announced a
     restructuring plan to signif