SecProbe.io

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                          [KIRKLAND & ELLIS LLP LOGO]

                             200 East Randolph Drive
                             Chicago, Illinois 60601
    Carol Anne Huff
To Call Writer Directly:           312 861-2000                 Facsimile:
     312 861-2163                                              312 861-2200
   chuff@kirkland.com            www.kirkland.com

                                 September 7, 2005

VIA EDGAR SUBMISSION AND
OVERNIGHT DELIVERY

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549
Attention:  Ms. Peggy A. Fisher

         Re:      Exide Technologies
                  Registration Statement on Form S-3
                  File Number 333-126619

Ladies and Gentlemen:

                  On behalf of Exide Technologies, a Delaware corporation (the
"Company"), we are writing to respond to the comment raised in your letter to
the Company dated July 27, 2005 with respect to the Company's Registration
Statement on Form S-3 which was filed with the Securities and Exchange
Commission (the "Commission") on July 15, 2005. Your comment is reproduced below
in italics for convenience.

REGISTRATION STATEMENT ON FORM S-3

FORM ELIGIBILITY

1.       We note the disclosures in your annual report on Form 10-K for the
         fiscal year ended March 31, 2005 regarding the various defaults under
         your credit agreement. Please provide us with your analysis as to
         whether you satisfy the eligibility requirements set forth in General
         Instruction I.A.5. of Form S-3 for the use of Form S-3. Include an
         analysis of whether the defaults accelerated your obligations and cite
         applicable provisions of exhibits filed with your annual report on Form
         10-K.
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                              KIRKLAND & ELLIS LLP

Securities and Exchange Commission
September 7, 2005
Page 2

         Response: The Company's failure to satisfy certain of the covenants in
         its Credit Agreement(1) over the past year has not affected the
         Company's eligibility to use Form S-3 because no covenant defaults by
         the Company have triggered accelerated payment obligations under the
         Credit Agreement. Under General Instruction I.A.5. of Form S-3, a
         registrant is not eligible to use Form S-3 if the registrant defaulted
         "on any installment or installments on indebtedness for borrowed
         money." Item XXXIII of Section G, "Securities Act Forms," in the
         Commission's Division of Corporate Finance Manual of Publicly Available
         Telephone Interpretations dated July 1997 confirms that "[a] default on
         a covenant not involving an 'installment on indebtedness' does not
         disqualify a company from using ... Form S-3. A default will only be
         disqualifying if it involves failure to pay principal or interest on a
         sinking fund installment."

                  Each of the Company's defaults under the Credit Agreement has
         been caused by the failure to satisfy financial covenants and
         information covenants as opposed to the failure to repay indebtedness.
         The Credit Agreement contains several financial maintenance covenants.
         These covenants require the Company to maintain a designated
         consolidated interest coverage ratio,(2) prohibit the Company from
         exceeding a designated leverage ratio,(3) require the Company to
         maintain a designated minimum consolidated EBITDA,(4) require the
         Company to maintain a designated minimum asset coverage ratio(5) and
         prohibit the Company from making capital expenditures in excess of a
         designated amount(6) (collectively, the "Financial Maintenance
         Covenants"). An information covenant in the Credit Agreement also
         requires the Company to furnish annually to the lenders the Company's
         audited financial statements and requires the Company's independent
         certified public accountants to certify such audited financial
         statements,

-----------------

(1) See the Credit Agreement dated as of May 5, 2004 among Exide Technologies,
    Exide Global Holding Netherlands C.V., Various Lending Institutions, Credit
    Suisse First Boston and Fleet Securities, Inc. and Deutsche Bank AG New
    York Branch (filed as Exhibit 10.1 to the Company's Current Report on Form
    8-K filed with the Commission on May 7, 2004) (referred to in this letter
    as the "Credit Agreement").

(2) See Section 9.08 of the Credit Agreement.

(3) See Section 9.09 of the Credit Agreement.

(4) See Section 9.10 of the Credit Agreement.

(5) See Section 9.11 of the Credit Agreement.

(6) See Section 9.12 of the Credit Agreement.

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                              KIRKLAND & ELLIS LLP

Securities and Exchange Commission
September 7, 2005
Page 3

         including that the audit was made without qualification or expression
         of uncertainty, in each case as to going concern(7) (the "Annual
         Financial Statements Covenant").

                  As described on pages 36 and 37 of the Company's Annual Report
         on Form 10-K filed with the Commission on June 29, 2005 (the "Form
         10-K), the Company has failed to satisfy the Financial Maintenance
         Covenants on various occasions throughout the past year and failed to
         satisfy the Annual Financial Statements Covenant with respect to the
         financial statements included in the Form 10-K.(8) However, these
         covenant breaches have not triggered or accelerated payment obligations
         under the Credit Agreement. Under the terms of the Credit Agreement,
         covenant defaults trigger payment obligations only upon the written
         request of lenders holding loans representing greater than 50% of the
         sum of all outstanding principal of loans made to the Company under the
         Credit Agreement (the "Required Lenders")(9). Furthermore, certain
         covenant defaults under the Credit Agreement (including, without
         limitation, the Annual Financial Statements Covenant) will not mature
         into an "Event of Default" unless such defaults continue unremedied for
         a period of at least 15 days after notice to the defaulting party by
         the administrative agent or any lender under the Credit Agreement.(10)
         None of the Company's defaults under the Financial Maintenance
         Covenants or the Annual Financial Statements Covenant triggered or
         accelerated any payment obligation because (i) with respect to the
         Annual Financial

-------------------

(7)      See Section 8.01(c) of the Credit Agreement.

(8)      The Company's defaults of the Financial Maintenance Covenants and the
         Annual Financial Statements Covenant were promptly waived by the
         lenders under the Credit Agreement. See (i) the First Amendment and
         Waiver to Credit Agreement dated as of November 10, 2004 among Exide
         Technologies, Exide Global Holding Netherlands C.V., the Lenders from
         time to time party thereto and Deutsche Bank AG New York Branch (the
         Lenders party thereto and Deutsche Bank AG New York Branch are
         collectively referred to in this letter as the "Lender Parties") (filed
         as Exhibit 4.3 to the Company's Quarterly Report on Form 10-Q for the
         quarterly period ended September 30, 2004); (ii) the Second Amendment
         and Waiver to Credit Agreement dated as of February 14, 2005 among
         Exide Technologies, Exide Global Holding Netherlands C.V. and the
         Lender Parties (filed as Exhibit 4.4 to the Company's Quarterly Report
         on Form 10-Q for the quarterly period ended December 31, 2004); (iii)
         the Fourth Amendment to Credit Agreement dated as of June 14, 2005
         among Exide Technologies, Exide Global Holding Netherlands C.V. and the
         Lender Parties (filed as Exhibit 99.1 to the Company's Current Report
         on Form 8-K filed with the Commission on June 15, 2005); and (iv) the
         Fifth Amendment and Waiver to Credit Agreement dated as of June 29,
         2005 among Exide Technologies, Exide Global Holding Netherlands C.V.
         and the Lender Parties (filed as Exhibit 99.2 to the Company's Current
         Report on Form 8-K filed with the Commission on June 30, 2005).

(9)      See Section 10 of the Credit Agreement.

(10)     See Section 10.03 of the Credit Agreement.

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                              KIRKLAND & ELLIS LLP

Securities and Exchange Commission
September 7, 2005
Page 4

         Statements Covenant, the Company did not receive notice of such
         defaults from the administrative agent or any lender under the Credit
         Agreement and (ii) with respect to the Financial Maintenance Covenants,
         the Company did not receive written notice from the administrative
         agent of the written request of the Required Lenders to accelerate any
         payment obligation under the Credit Agreement. Accordingly, the Company
         did not default on any "installment or installments on indebtedness for
         borrowed money" under General Instruction I.A.5. of Form S-3, and the
         Company remains eligible to use Form S-3.

                                    * * * * *

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                              KIRKLAND & ELLIS LLP

Securities and Exchange Commission
September 7, 2005
Page 5

                  Please do not hesitate to contact the undersigned at the
number above with any questions or comments regarding this filing.

                                                     Sincerely,

                                                     /s/  Carol Anne Huff
                                                     ---------------------------
                                                     Carol Anne Huff

cc:      Stuart H. Kupinsky
         Exide Technologies

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