SecProbe.io

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Mail Stop 0407

      							December 17, 2004

Via U.S. Mail and Fax
Mr. Jeffrey L. Wright
Senior Vice President and Chief Financial Officer
G&K Services, Inc.
5995 Opus Parkway
Minnetonka, MN  55343

	RE:	G&K Services, Inc.
      Form 10-K for the fiscal year ended July 3, 2004
		Filed September 16, 2004
		File No. 0-04063

Dear Mr. Wright:

      We have reviewed the above referenced filings and have the
following comments.  We have limited our review to only the issues
addressed below and will make no further review of your documents.
As such, all persons who are responsible for the adequacy and
accuracy of the disclosure are urged to be certain that they have
included all information required pursuant to the Securities
Exchange
Act of 1934.  Please revise your filings to address the following
comments.  If you disagree, we will consider your explanation as
to
why our comment is inapplicable or a future revision is
unnecessary.
Please be as detailed as necessary in your explanation.  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.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the fiscal year ending July 3, 2004

Note 1.  Summary of Significant Accounting Policies, page F-6

      Goodwill, Intangible and Long-Lived Assets, page F-7

1. Please expand your disclosure so that it is clear how you
distinguish in your accounting between acquired customer contract
intangible assets and acquired customer relationship intangible
assets, and advise us.  Refer to paragraphs A19 - A21 of SFAS 141
and
paragraph 11 of EITF 02-17.  Also, tell us if you account for each
acquired customer contract as a separate intangible asset.

2. We note you amortize acquired customer contracts and related
customer relationships over the terms of the respective agreements
or
estimated average life of the account, primarily 5 to 11 years.
Disclose your amortization methodology for each asset type and
advise
us.  If you are amortizing customer contracts or customer
relationships on a straight-line basis, please justify this policy
to
us.  Refer to the guidance in paragraph 12 of SFAS 142 and tell us
how your amortization policy is consistent with the pattern in
which
economic benefits of the intangible assets are consumed or
otherwise
used up.

3. In regard to the above comments, we believe you should account
for
each acquired customer contract on an individual basis.  This
model
would allow the company to use straight-line amortization over the
expected life but would require that amounts pertaining to
terminated
contracts be written off at the time the contracts are terminated.
The company could pool the contracts for bookkeeping purposes, but
the expected life determination and the impairment analysis would
need to be performed at the individual contract level.

4. If management believes the implementation of this model to be
impracticable, we would not object to the company assigning each
contract to a pool of sufficiently homogeneous contracts and the
asset accounted for in the financial records would be the pool,
not
the contract.  This method would require the use of an accelerated
amortization method to reflect the greater revenue earning power
during the earlier years of the pool`s life.  The expected life
determination and the impairment analysis would be performed at
the
pool level, and thus, no specific write-offs for terminated
contracts
would be necessary.

5. Similarly, it appears you should amortize for your customer
relationship intangible assets using an accelerated method since
the
economic benefits to be realized from this asset will diminish
over
time as your relationships with customers terminate.  Please
revise
your financial statements accordingly or advise us.

Note 2.  Acquisitions, page F-10

6. You are required, pursuant to paragraph 39 of SFAS 141, to
record
all acquired identifiable intangible assets at their respective
fair
values.  Disclose and explain to us, in detail, why the majority
of
your purchase price for acquisitions consummated during the past
three years and subsequent interim period has been assigned to
goodwill.  When responding to this comment, please refer to the
list
of identifiable intangible assets in paragraph A14 of SFAS 141 and
explain to us why you do not apparently acquire any marketing
related
intangible assets, order or production backlog, licensing or
royalty
agreements, leases, contracts, or technology based intangible
assets.

7. In addition, with respect to each acquisition explain to us its
purpose and how management determined the amount of consideration
paid was reasonable.  Tell us the methodologies used by management
to
determine the amount of purchase consideration to pay for each
acquired entity and the methodologies used to assign value to any
acquired intangible assets.

8. Revise your disclosures to comply with paragraphs 51-53 of SFAS
141.

Note 3.  Goodwill and Intangible Assets, page F-10

9. Using the guidance in paragraphs 30-31 of SFAS 142, tell us how
you determined your reporting units for purposes of performing
your
goodwill impairment test.  Additionally, tell us how you have
determined the amount of goodwill to be assigned to your separate
reporting units.

10. Tell us in more detail how you performed the impairment test
for
each of your reporting units at the date of adoption of SFAS 142
and
in 2004.   Your response should include a detailed discussion of
the
methodology used to determine the fair value of each of your
reporting units, as well as a discussion of the key assumptions
used
in determining the fair value, such as cash flow projections and
discount rates.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested supplemental information.  Please file your response
letter
on EDGAR.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating 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 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 filings; 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 advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Kathleen Kerrigan, Staff Accountant, at
(202)
942-1944 or Robert S. Littlepage, Accountant Branch Chief, at
(202)
942-1947 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 942-
1990
with any other questions.

							Sincerely,

							Larry Spirgel
							Assistant Director
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Mr. Jeffrey L. Wright
G&K Services, Inc.
December 17, 2004
Page 4

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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