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CORRESP
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August 22, 2005

By EDGAR

Securities and Exchange Commission
450
Fifth Street, N.W., Mail Stop 0309
Washington, D.C. 20549

Attn:
Joe Kempf, Staff Accountant
              Joe Cascarano, Staff Accountant

Re:
       UniFirst Corporation
               Form 10-K for the
fiscal year ended August 28, 2004
               Filed November 12, 2004
               File
No. 001-08504

Ladies and Gentlemen:

        This
letter is submitted on behalf of UniFirst Corporation, Inc. (the “Company”), 68
Jonspin Road, Wilmington, MA, 01887, in response to the comments of the staff of the
Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) with respect to the Company’s Annual Report
on Form 10-K for the fiscal year ended August 28, 2004 (the
“Form 10-K”), as set forth in a letter dated August 4, 2005 to John B.
Bartlett (the “Comment Letter”) and comments of the Staff during a phone call
with Steven S. Sintros (Corporate Controller) on August 4, 2005.

        For
reference purposes, the text of the Comment Letter has been reproduced herein with
responses below each numbered comment. For your convenience, we have italicized the
reproduced Staff comments from the Comment Letter and we have bolded the headings of our
responses thereto.

Comment No. 1

We note your statement that your
“disclosure controls and procedures are effective to ensure that material information
relating to the Company required to be disclosed by us in the reports that we file or
submit under the Exchange Act is recorded, processed, summarized and reported, within the
time periods specified in the Commission’s Rules and forms.” Since you restated
your financial statements for the year ended December 31, 2004 (August 28, 2004), it
appears that your disclosure controls and procedures were ineffective as of December 31,
2004 (August 28, 2004). Please revise, or tell us why you believe they were effective.

Response to Comment No. 1

        The
Company views its internal controls over financial reporting as a component of its overall
disclosure controls and procedures and therefore, is responding to the Staff’s
comments in that context. The Company has concluded that its disclosure controls and
procedures were effective as of August 28, 2004 as the Company believes that the failure
to include information omitted and subsequently included in the Company’s Form 10-K/A
filing on July 28, 2005 (Form 10-K/A) did not represent a material weakness in its
internal controls over financial reporting which caused its disclosure controls and
procedures to be deemed ineffective. While the SEC Staff has not issued specific
interpretive guidance regarding disclosure controls and procedures, in the May 16, 2005
Staff Statement on Management’s Report on Internal Controls Over Financial Reporting,
the SEC staff asserted, “Neither Section 404 nor the Commission’s implementing
rules required that a material weakness in internal controls over financial reporting must
be found in every case of restatement resulting from an error. Rather, both management and
the external auditor should use their judgment in assessing the reasons why a restatement
was necessary and whether the need for restatement resulted from a material weakness in
controls. Such an evaluation should be based on all the facts and circumstances, including
the probability of occurrence in light of the assessed effectiveness of the company’s
internal control, keeping in mind that internal control over financial reporting is
defined as operating at the level of reasonable assurance.” The Company
continues to believe that its disclosure controls and procedures are effective to ensure
that material information relating to the Company that is required to be disclosed
by us in reports we file or submit under the Exchange Act is recorded, processed,
summarized and reported within the time periods specified in the Securities and Exchange
Commission rules and forms.

        The
Company conclusion is based on the following information:

               A.

               The amendment to the Form 10-K was the result of a different interpretation of
               the disclosure requirements of SFAS 131, not the result of ineffective
               disclosure controls and procedures.

               B.

               None of the additional disclosures included in the Company’s Form 10-K/A
               affected or changed the Company’s previously reported consolidated
               revenues, net income, income per share or other results of operations and did
               not require restatement of the basic consolidated financial statements (Balance
               Sheets, Statements of Income, Shareholders’ Equity and Cash Flows).

               C.

               While the expanded disclosures provide additional information, that additional
               information was consistent with previous disclosures in Item I
               “Business” and Item 7 “Management’s Discussion and Analysis
               of Financial Condition and Results of Operations”.

               D.

               The additional disclosure in the Form 10-K/A did not result in any questions or
               comments from shareholders or analysts regarding the additional information
               presented in the Form 10-K/A or a significant fluctuation of the Company’s
               stock price surrounding its press release announcing the amendment of its Form
               10-K or the actual filing of the amendment.

               E.

               The Company consulted with Ernst & Young LLP, its independent registered
               public accounting firm, including its national office regarding this matter.
               Ernst & Young LLP agreed with the Company’s conclusion that the failure
               to include the information omitted and subsequently included in the
               Company’s Form 10-K/A did not represent a material weakness in its internal
               controls over financial reporting which caused its disclosure controls and
               procedures to be deemed ineffective.

        After
evaluating the above information, the Company reconsidered its disclosure in Item 9A.
“Controls and Procedures” and continues to believe its disclosure controls and
procedures are effective to ensure that material information relating to the
Company that is required to be disclosed by us in reports we file or submit under the
Exchange Act is recorded, processed, summarized and reported within the time periods
specified in the Securities and Exchange Commission rules and forms.

Comment No. 2

In the Company’s response
dated March 11, 2005 to the Staff’s letter dated February 18, 2005, the Company
stated that, Pursuant to the Rule 5-03(b)(1) of Regulation S-X, the Company will state
separately on its Statement of Income, revenues and operating costs for the following
categories; “Rental and Cleaning” and “Direct Sales” in future
filings. The “Direct Sales” category will include sales and cost of sales as
applicable, related to the direct sale of first-aid cabinet services and safety supplies
and direct sale of garments, non-garment items and specialty garments.” The Staff has
asked the Company to include such disclosure in filings going forward or to explain to the
Staff why such disclosures are not required.

Response to Comment No. 2

        The
Company has subsequently determined that based on the guidance in Rule 5-03(b)(1) that
Direct Sales revenues and costs are not required to be disclosed separately as they are
less than 10% of total revenues. Therefore, the Company will continue to disclose one line
each for revenues and costs of sales in future filings.

If you should have any questions
about this letter, please call the undersigned at (978) 658-8888.

     Very truly yours,

By:  /s/ John B. Bartlett

        John B. Bartlett,

        Senior Vice President and

        Chief Financial Officer