SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
					October 26, 2005

Frederick G. Anderson
Vice President - General Counsel
Texas Industries, Inc.
1341 West Mockingbird Lane, Suite 700W
Dallas, Texas  75247-6913

	Re:	Texas Industries, Inc.
      Form S-4 filed September 30, 2005
      File No. 333-128736

Dear Mr. Anderson:

      We have limited our review of your filing to those issues we
have addressed on our comments.  Where indicated, we think you
should
revise your documents in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a 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 information so we may better understand
your
disclosure.  After reviewing this information, we may 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.

General

1. Provide us with an executed supplemental letter that:
* states you are registering the exchange offer in reliance upon
the
relevant Exxon Capital no-action letters, and
* includes the representations substantially in the form set forth
in
the Morgan Stanley and Shearman & Sterling no-action letters.

Exhibit 5.1 - Thompson & Knight Legal Opinion

2. We are unsure what you mean by the clause in paragraph (a) on
page
2 of the opinion that begins "and except as rights to indemnity
and
contribution . . ." Please either remove this clause or explain it
supplementally, but note that we may have additional comments.
3. Please delete the qualification you have included in paragraph
(b)
on the second page of the opinion.  Counsel should opine on the
enforceability of all provisions of the indenture and notes.

4. Since counsel is also opining that the securities are duly
authorized, the opinion cannot be limited to Texas law.  Some of
the
guarantors are incorporated in Louisiana, Virginia, Delaware, and
California. Please revise.

	As appropriate, please amend your filing in response to these
comments.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

      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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert this action 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 connection with our review of your
filing or
in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Brigitte Lippmann at (202) 551-3713 or me at
(202) 551-3760 if you have any questions.

Sincerely,

Pamela A. Long
Assistant Director

cc:	Joe Dannenmaier
      Thompson & Knight L.L.P.
 	1700 Pacific Avenue, Suite 3300
      Dallas, Texas 75201

??

??

??

??

Frederick G. Anderson
Texas Industries, Inc.
October 26, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>