SecProbe.io

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							November 14, 2005

Mail Stop 3561

Mr. Thomas R. McGuire, Chairman and Chief Executive Officer
The Coast Distribution System, Inc.
350 Woodview Avenue
Morgan Hill, California 95037

Re:	The Coast Distribution System, Inc. (the "Company")
	Form 10-K for the year ended December 31, 2004
      File No. 001-09511

Dear Mr. McGuire:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  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
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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Management`s Discussion & Analysis

Results of Operations - page 12
1. Pursuant to FR-72, you should consider revising the disclosures
in
MD&A with respect to the following general areas:

* The overall presentation of MD&A, with a particular focus on
providing an executive-level overview; and

* The focus and content of MD&A (focus on material information,
identification and disclosure of known trends and uncertainties,
discussion and analysis of both past and prospective financial
matters).

Where changes in revenue and gross margin results are attributed
to
more than one factor, please revise to quantify the impact of each
factor where practicable.  For example, you state that the
increase
in revenues during 2004 is a result of increased demand for RV
products, increased demand for Coast proprietary products, and
improvements in service levels. You also note that gross margin
increased due to a change in the mix of products, price increases,
continued strengthening of the Canadian dollar, and lower average
costs due to greater sales volume. In addition to quantifying each
of
these items, consider discussing how these improvements were
achieved
and whether you expect these trends to continue.

Liquidity and Capital Resources - page 14

2. In accordance with Regulation S-K, Item 303 (a)(5), please
provide
a tabular presentation of your known contractual obligations.
3. Please add disclosure with respect to any material unused
sources
of liquidity. See Item 303 (a)(1) of Regulation S-K.

Item 7A Quantitative and Qualitative Disclosures about Market Risk
-
page 18
4. Given that approximately 24% of your debt is denominated in
Canadian currency and interest expense appears material in
relation
to your operating results, please provide quantitative information
about currency exchange and interest rate risk in accordance with
one
of the three disclosure alternatives outlined in Regulation S-K,
Item
305(a).

* * * * *

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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 supplemental 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 filing 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 filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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 filing or in
response to our comments on your filing.

	You may contact Rob Perdue at (202) 551-3303 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact Rob Perdue or me at with any other
questions.

Sincerely,

David R. Humphrey
Branch Chief

Via Facsimile: Mrs. Sandra Knell, CFO
		(408) 782-8601
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Mr. Thomas McGuire.
The Coast Distribution System, Inc.
November 14, 2005
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