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    773.890.1010

    FAX 773.890.0523

    4501 West 47th Street

    Chicago, Illinois 60632

October
3, 2005

Ms. Meagan Caldwell

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-7010

    Re:

    Home Products International, Inc.

Form 10-K/A for the Fiscal Year Ended January 1, 2005

Form 10-Q/A for the Fiscal Quarter Ended April 2, 2005

Filed: September 16, 2005

File No. 333-25871

Dear Ms. Caldwell:

     We are responding to your letter dated September 22, 2005 (the “Comment Letter”). To
facilitate your review, the comment in the Comment Letter is set forth below in bold type and our
corresponding response appears below it in ordinary type.

We reviewed your Form 10-K/A for the fiscal year ended January 1, 2005 and Form 10-Q/A for
the fiscal quarter ended April 2, 2005. Based on your disclosures related to the lease
accounting and Mexican subsidiary adjustments, it appears as though these adjustments in
aggregate had a material impact to your loss before income taxes. net loss, and loss per
common share for the fiscal year ended January 1, 2005. Please tell us what consideration
you have to this and any additional factors you considered in concluding that the
restatements related to lease accounting and Mexican subsidiary adjustments did not
constitute a material weakness.

     Response:  In response to the Staff’s comment, we advise the Staff that a number of
factors were considered in concluding that the restatement adjustments related to lease accounting
and the Mexican subsidiary did not constitute a material weakness.

     First, since a material weakness is defined as a control deficiency, or combination of control
deficiencies, that results in a more than remote likelihood that a material misstatement of annual
or interim financial statements will not be prevented or detected, we examined the materiality of
such adjustments and the manner in which such adjustments were identified. This examination was
made in the context that we no longer have any publicly-traded equity

securities. We are presently
a voluntary filer pursuant to a contractual requirement under our bond indenture. Due to the
nature of our outstanding indebtedness (bonds and an outstanding bank credit facility), our
financial performance is primarily measured on cash-flow based measures rather than net income. For example,
our bank credit facility uses an EBITDA calculation (“Bank EBITDA”). Management incentive plans
are also based on these same calculations. However, since these are non-GAAP financial measures
and are not reported in our financial statements, we evaluated the impact of these adjustments as
to their effect on our consolidated cash flow.

     None of the adjustments individually, or in the aggregate, had any impact on the net cash
(used by) provided from operations. Consequently, given the financial metrics most material to our
business, bondholders and banks, such adjustments did not present a material misstatement of our
financial statements.

     Although we noted that the aggregate impact in all prior periods of all such adjustment on net
income was approximately $0.48 million, or approximately 6.0% of net loss for the fiscal year ended
January 1, 2005, and was only 5.6% of operating income and 0.2% of total revenues, this adjustment
reflected an aggregate of prior years and, as noted above, did not constitute a material
misstatement. Moreover, the nature of the adjustments were very different and are more accurately
viewed in their individual contexts.

     For example, the lease adjustment related to a 10 year lease that was entered into in 2000 and
represented an aggregate adjustment of approximately $0.25 million covering a period of five years.
While this amounted to approximately 3.2% of net income for the fiscal year ended January 1, 2005,
it was only 2.9% of operating income and 0.1% of total revenues. The amounts applicable to prior
years was less than 2% of accrued liabilities in each of such years and in none of such periods
would such adjustment have had the effect of changing our financial position from a gain to a loss
or vice versa nor would it have changed retained earnings to a deficit. In addition, this
adjustment would not have had any impact on covenants, bank borrowing capacity or bonuses paid in
any of the fiscal years affected. Finally, and most importantly, since our reported expense was
equal to the cash payments, there was no effect on cash from operations or cash on hand – another
significant metric for readers of our financial statements.

     Furthermore, from a covenant compliance standpoint, the adjustments had less than a 2% impact,
as determined using the Bank EBITDA calculations made under the credit facility. Such adjustments
did not have any effect on our compliance with any bank covenants, debt payments or management
incentives that were paid out during the period.

     Accordingly, in the opinion of management, the lease adjustments were not material to our
financial position or results of operations and to have adjusted each individual period would
likely have caused more confusion to the readers of our financial statements and would not have
added any value to the investment decisions made by those readers, particularly given the absence
of any public trading of our equity securities.

     Second, from a qualitative perspective, we identified and discovered the inadvertent error in
a five year old lease through the application of our controls and procedures in connection with our
review of a new, upcoming lease (which was calculated correctly). Since we do not have public
equity and are not an accelerated filer, we are not subject to the full application of Rule 404

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to
our internal controls and procedures. However, due to the controls and procedures currently in
place, in connection with the review of a new lease, we also examined the accounting treatment
applicable to all existing leases. When our current procedures were applied, they were sufficient
not only to assure the application of the appropriate accounting pronouncements and treatment to
the new lease, but also to identify the error in accounting treatment for the prior lease. These
procedures confirmed that the error resulting in the adjustment was an isolated incident and that
the proper accounting treatment was applied to our other leases. Therefore, we believe that our
controls and procedures did operate effectively to identify and prevent misstatements in our
financial statements and therefore did not constitute a material weakness.

     With regard to our Mexican subsidiary adjustments, as disclosed, we discovered that we had
unintentionally understated depreciation expense on assets located in our Reynosa, Mexico facility.
The aggregate amount of the error occurring over a seven year period was approximately $0.18
million, or an average of $0.025 million per year. Although the total aggregate amount of $0.18
million represented 2.3% of net loss for 2005, it was a non-cash adjustment that represented less
than 1% of fixed assets and 2% of total depreciation expense in 2005. Furthermore, when viewed on
an individual yearly basis, such amount was clearly insignificant.

     More importantly, as with the lease adjustment, in none of such periods would such adjustment
have had the effect of changing our financial position from a gain to a loss or vice versa nor
would it have changed retained earnings to a deficit. In addition, this adjustment would not have
had any impact on covenants, bank borrowing capacity or bonuses paid in any of the fiscal years
affected. Finally, there was no effect on cash from operations or cash on hand, which, as we noted
above, are significant metrics for readers of our financial statements.

     Analyzing the error from a qualitative perspective as it relates to our internal controls,
this error originated with the accounting at the time of the original purchase of the facility
seven years ago and was detected through the application of our current controls and procedures.
These procedures confirmed that the error resulting in the adjustment was an isolated incident and
that the proper accounting treatment was applied to our other assets at the Reynosa facility.
Combined with the minimal amount involved on an annual basis (approximately $0.025 million),
management believes that our internal controls and procedures were effective in preventing any
misstatement of our financial statements and therefore did not constitute a material weakness.

     The final adjustment for currency translation related to our Reynosa, Mexico facility. This
adjustment in the amount of $0.05 million resulted from confusion regarding the appropriate
functional currency to be used in our financial statements. After further review of FAS 52 and
adjusting to reflect the U.S. dollar rather than the Mexican peso as
the functional currency,
various financial statement adjustments were required. It should be further noted that this
adjustment occurred completely within the year of 2004, did not affect any prior periods and had
less than a 1% impact under all applicable measures noted above. Once again, we concluded that the
adjustment was not material and the underlying error was identified through the application of our
internal controls and procedures. Therefore, we do not believe that this adjustment reflected a
material weakness to our financial statements.

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     For the reasons set forth above, as a voluntary filer with no publicly traded equity
securities, we do not believe, whether viewed from the perspective of an individual adjustment or a
combination of adjustments, that such adjustments constituted a material weakness in our internal
controls and procedures. If you have any further questions or comments, please do not hesitate to
contact me or our legal counsel David S. Stone at Neal, Gerber & Eisenberg LLP at 312-269-8411.

    Very truly yours,

/s/
Donald J. Hotz

    Donald J. Hotz

    Chief Financial Officer

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