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                       [THOR INDUSTRIES, INC. LETTERHEAD]

December 21, 2004

Mr. Michael Fay
U.S. Securities and Exchange Commission
Division of Corporate Finance
Washington D.C. 20549-0305

Re:  Thor Industries, Inc.
     File No. 001-09235
     Form 10-K for the year ended July 31, 2004

Dear Mr. Fay,

The following are responses to the staff comment letter dated December 8, 2004.
For convenience of reference, the responses are organized using the same
headings and numbered captions as your letter.

Management's Discussion and Analysis, page 11
---------------------------------------------

Fiscal 2004 vs. Fiscal 2003, page 13
------------------------------------

1.       Excluding Damon, our revenue increased in fiscal 2004 by $406,227,710
         or 25.9% for the following reasons:

         Motor home sales increased in fiscal 2004 compared to fiscal 2003 by
         $143,676,006. New diesel motor homes produced and sold accounted for
         $62,155,677 of the increase. The balance of the increase in motor home
         sales was from increased demand.

         Our towable recreation vehicles increase in revenues of $264,811,768
         were due primarily to the overall industry market increase of 15.5%.

         Our bus revenues were down in fiscal 2004, compared to fiscal 2003, by
         $2,260,064 or 1.0%, due primarily to reduced unit sales and
         competition.

 2.      The $6,500,000 amount is comprised of a $1,000,000 property insurance
         charge and product liability reserve of $5,500,000. The property
         insurance charge of $1.0 million relates to the amount of the
         deductible for damage resulting from a fire that occurred at our
         Airstream facility during the fourth quarter of 2004. The product
         liability reserve includes a reserve for two product liability cases
         for $5,500,000 involving wrongful death claims. We explored the facts
         and circumstances of the matters and after consultation with legal
         counsel concluded

<PAGE>

         during the fourth quarter that it was probable that a liability had
         been incurred. Accordingly, we recorded the obligations in the fourth
         quarter. Both of these cases have been subsequently settled during the
         first quarter of fiscal 2005 for a total of $5,350,000.

         Product and property related liability reserves are reviewed monthly by
         management and outside counsel. Reserves are adjusted as the facts and
         circumstances change.

Consolidated Financial Statements, page 23
------------------------------------------

Consolidated Balance Sheets, page 25
------------------------------------

3.       The significant components of "other" accrued liabilities were:

<TABLE>
<CAPTION>
                                                           As of                As of
                                                       July 31, 2004        July 31, 2003
                                              --------------------------------------------
<S>                                                     <C>                   <C>
         Accrued Promotions/Rebates                    $  8,915,220           $ 3,579,704
         Accrued Legal                                    1,104,367             1,373,649
         Accrued Product/Property Liability               9,951,385             1,523,000
         Accrued Freight                                  1,773,350             1,384,383
         Accrued Other                                    2,016,974             1,526,653
                                              --------------------------------------------
                 Total                                 $ 23,761,296           $ 9,387,389
                                              ============================================
</TABLE>

         None of these components of "other" accrued liabilities exceeds 5% of
         total current liabilities and thus are not separately disclosed in
         accordance with Regulation S-X 5.02.20.

Note A - Summary of Significant Accounting Policies, page 29
------------------------------------------------------------

Stock Options, page 30
----------------------

4.       In future filings we will disclose, if material, the number of options
         and restricted shares that could potentially dilute our basic earnings
         per share in future periods but were not included in the computation of
         diluted earnings per share because their impact was anti-dilutive. For
         information purposes, as of July 31, 2004, the number of anti-dilutive
         options was 29,000 and there were no anti-dilutive restricted shares.

<PAGE>
Note I - Contingent Liabilities and Commitments, page 35
--------------------------------------------------------

5.       Thor has been required to repurchase recreation vehicles in the
         approximate amount of $6,209,000, $3,855,000 and $4,028,000 for fiscal
         years 2004, 2003 and 2002, respectively. We will disclose this
         information in future filings.

         We do not sell product to dealers who are in default other than as
         required by various state franchise laws and then only on a cash on
         delivery basis.

6.       Management does not believe it has risk of ownership to chassis used in
         its bus segment prior to the time it puts the vehicle into bus
         production, because it does not have title to the vehicle, must store
         it in a secure location for the benefit of the manufacturer and may not
         use or dispose of the vehicle except with the chassis manufacturer's
         consent or pursuant to the terms of the agreement with the
         manufacturer.

         Chassis for our bus division are acquired, for example, under the Ford
         Authorized Converter Pool Agreement. The transactions operate as
         follows:

         Ford "sells" the vehicle to us and Ford Credit advances the price to
         Ford. We are obligated to store the vehicle in a locked, segregated
         location. Ford retains the Certificate of Origin (title) to the
         vehicle. We do not have the right to sell the vehicle, except to Ford.
         When we want to use the vehicle in production, we notify Ford, which
         repurchases the vehicle. Ford has the legal right to sell the vehicle
         to any of its dealers or other manufacturers. In practice, at such time
         as we put this chassis into production, Ford transfers the title to a
         Ford Dealer, which transfers title to us, and we pay the purchase price
         for the vehicle.

         Our agreement with Ford Credit provides that our possession of the
         vehicles "shall be for the sole purpose of storing the same." We assume
         risk of loss only to the extent that Ford Credit is not fully
         reimbursed for loss under its own insurance policy.

Note L - Joint Ventures, page 37
--------------------------------

7.       The following Schedule presents certain financial information for Thor
         Credit Corporation ("Thor Credit") and CAT Joint Venture LLC ("CAT
         LLC") at July 31, 2004 and for the year then ended:

<TABLE>
<CAPTION>
                              Thor Credit               CAT LLC
                              -----------               -------
<S>                           <C>                     <C>
         Total Assets         $10,334,112             $9,665,352
         Equity                 2,329,913              1,278,984
         Revenues              14,328,869              4,331,102
</TABLE>

<PAGE>

         Our evaluation of Thor Credit and CAT LLC as potential variable
         interest entities under FIN 46(R) resulted in the following
         conclusions:

         Thor Credit was deemed to qualify for scope exceptions under paragraph
         4(h) of FIN 46(R). Thor Credit is a 50/50 joint venture between Thor
         Industries ("Thor") and Ganis Credit Corporation ("Ganis"), a
         wholly-owned subsidiary of E*TRADE Financial Corp. Thor Credit is
         deemed to be a business under the definition of Appendix C, in that it
         is a self-sustaining integrated set of activities and assets conducted
         and managed for the purpose of providing a return to investors. In
         addition, the provisions of paragraphs 4(h) 1,2,3 and 4 are satisfied
         as follows: 1) Thor Credit is an operating joint venture under joint
         control. 2) Thor Credit was not designed so that substantially all of
         its activities either involve or are conducted on behalf of Thor or its
         related parties. 3) Thor and Ganis each provided equal amounts of
         capital to Thor Credit and no other subordinated debt or other forms of
         financial support. 4) The activities of Thor Credit are to finance the
         sales of recreation vehicles to consumer buyers and sell the loans to
         financial institutions and not securitizations or other forms of
         asset-backed financings or single-lessee leasing arrangements.

         CAT LLC met scope exceptions (1), (2) and (4) of paragraph 4(h) of FIN
         46 (R); however, it did not meet the scope exception of (3) of
         paragraph 4(h).

         CAT LLC is a 50/50 joint venture between Thor and Cruise America, Inc.
         ("Cruise"). CAT LLC is deemed to be a business under the definition of
         Appendix C, in that it is a self-sustaining integrated set of
         activities and assets conducted and managed for the purpose of
         providing a return to investors. In addition, the provisions of
         paragraphs 4(h) 1,2,3 and 4 are addressed as follows: 1) CAT LLC is an
         operating joint venture under joint control. 2) CAT LLC was not
         designed so that substantially all of its activities either involve or
         are conducted on behalf of Thor or its related parties. 3) Thor and
         Cruise each provided equal amounts of capital to CAT LLC. Thor also
         provided a subordinated note payable that had an outstanding balance of
         $710,000 at July 31, 2004. The note payable is due upon demand and
         bears interest at the same rate as CAT LLC's bank line of credit, which
         is the Domestic Rate plus .25%. 4) The activities of CAT LLC are to
         rent recreation vehicles to the public and not securitizations or other
         forms of asset-backed financings or single-lessee leasing arrangements.

         As a result of CAT LLC not meeting all the exceptions of paragraph
         4(h), our evaluation included the provisions of paragraph 5 to
         determine if any of the conditions described in a, b or c exist. We
         determined that the condition described in paragraph 5a did not exist
         and that CAT LLC's total equity investment at risk is sufficient. As
         required by paragraph 5a (1), CAT LLC's equity at risk only included
         the capital investments made by Thor and Cruise, plus retained
         earnings. CAT LLC's equity does not include any of the types of equity
         described in paragraphs 5a (2), 5a (3) and 5a (4). To further assess
         the sufficiency of CAT LLC's equity, we referred to Paragraph 9, which
         discusses the qualitative and quantitative considerations in
         determining the amount of total equity investment at risk that is
         necessary to permit an entity to

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         finance its activities without additional subordinated financial
         support. Paragraph 9 states "An equity investment at risk of less than
         10 percent of the entity's total assets shall not be considered
         sufficient to permit the entity to finance its activities without
         subordinated financial support in addition to the equity investment
         unless the equity investment can be demonstrated to be sufficient. The
         demonstration that equity is sufficient may be based on either
         qualitative analysis or quantitative analysis or a combination of
         both." The qualitative assessment is described in paragraphs 9(a) and
         9(b) and the quantitative assessment is described in 9(c). Paragraph
         9(a)- We believe that CAT LLC has the ability to finance its activities
         without additional subordinated financial support. Based upon CAT LLC's
         past negotiations with its bank, they believe that their bank's lending
         decision is based primarily on CAT LLC'historical operating history and
         the quality of the vehicle inventory. Paragraph 9(b)- We believe that
         CAT LLC's equity level is similar to other vehicle leasing and vehicle
         dealership entities. The ability to operate with such high leverage,
         results from lenders willingness to provide high ratios of loans to
         collateral. Paragraph 9(c) -Based upon the results of our analysis of
         the qualitative factors related to paragraphs 9(a) and 9(b), we did not
         deem it necessary to perform the quantitative analysis.

         We determined that the conditions described in paragraphs 5b(1), (2)
         and (3) did not exist based upon the following: (1) Thor and Cruise
         have the direct ability through voting rights to make decisions about
         CAT LLC's activities that have a significant effect on the success of
         the entity. (2) Thor and Cruise share the obligation (50/50) to absorb
         the expected losses of CAT LLC. (3) Thor and Cruise have equal rights
         to receive expected residual returns of CAT LLC.

         We determined that the conditions described in 5c did not exist because
         both Thor and Cruise's voting rights are proportional to their
         obligations to absorb the expected losses of CAT LLC and their rights
         to receive the expected residual returns of the entity. We considered
         the repurchase obligation that we have with CAT LLC's financial
         institution in connection with the provisions of 5c and concluded that
         our exposure to loss is not disproportionate due to the written
         agreement with Cruise, that any losses resulting from the vehicle
         repurchase obligation will be shared by the joint venture partners
         equally.

         Based upon our evaluation of the criteria referred to above, we believe
         that our investment in CAT LLC does not meet the provisions of
         paragraph 5 of FIN 46(R) and is not subject to consolidation.

8.       Thor Credit does not finance any Thor Industries sales to its
         customers. Thor Industries' customers are independent dealers, not
         consumer buyers, who either pay C.O.D., utilize floor planned financing
         with various institutions that they arrange, or in a rare case pre-
         approved open account. Thor Credit finances the sale of recreational
         vehicles to consumer buyers who are referred by independent dealers.

<PAGE>

         The amount of receivables that were outstanding at July 31, 2004 and
         2003 on Thor Credit's balance sheet were $248,594 and $311,910,
         respectively. Thor Industries has not guaranteed any of these
         receivables.

         Thor Industries' equity in the net income/(loss) of Thor Credit and CAT
         LLC for the years ended July 31, 2004, 2003 and 2002 are as follows:

<TABLE>
<S>                             <C>             <C>            <C>
         Thor Credit            $163,354        $66,453        $89,891
         CAT LLC                $282,962        $64,970       ($95,094)
</TABLE>

         The equity in net income/(loss) was included in the Other Income
         caption of Thor Industries' Consolidated Statements of Income.

Other
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9.       We unders