SecProbe.io

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								May 17, 2005

Mail Stop 0510

By U.S. mail and facsimile to (713) 644-3167

Ms. Tina S. Kirbie
Chief Financial and Accounting Officer
Handy Hardware Wholesale, Inc.
8300 Tewantin Drive
Houston, TX  77061

	RE:  	Form 8-K Item 4.01 filed April 28, 2005
		Form 8-K/A Item 4.01 filed May 16, 2005
		File # 000-15708

Dear Ms. Kirbie:

      We have reviewed your filing and have the following
comments.
If you disagree, we will consider your explanation as to why our
comments are inapplicable.  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
number
listed at the end of this letter.

1. In consideration of our prior comment number two, we have
noted
that you have filed your Form 10-Q for the period ended March
31,
2005, however your disclosure still states, "Clyde D. Thomas
would
continue to act as the Company`s independent public accountant
and
assist in the review of the Company`s financial statements for
the
quarter ended March 31, 2005..."  Your disclosure should include
a
statement that describes when the services of your former
accountant have ended.  In addition, the interim period date in
your disclosure should be updated for this effective end date.

Exhibit 16:

2. To the extent that you make changes to the Form 8-K to comply
with our comments, please obtain and file an updated Exhibit 16
letter from the former accountants stating whether the
accountant
agrees with the statements made in your revised Form 8-K.

*  *  *  *  *

	We urge all persons who are responsible for the accuracy
and
adequacy of the disclosure in the filing reviewed by the staff
to
be certain that they have provided all information investors
require.  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 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
filing
or in response to our comments on your filing.

      Please file your supplemental response via EDGAR in
response
to these comments within 5 business days of the date of this
letter.  Please note that if you require longer than 5 business
days to respond, you should contact the staff immediately to
request additional time.  You may wish to provide us with marked
copies of each amended filing to expedite our review.  Direct
any
questions regarding the above to the undersigned at (202) 824-
5525.

								Sincerely,

								Ryan Rohn
								Staff Accountant
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Ms. Tina S. Kirbie
Handy Hardware Wholesale, Inc.
May 17, 2005
Page 1 of 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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