SecProbe.io

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Mail Stop 6010
      November 17, 2005

By U.S. Mail and Facsimile to (847) 945-5698

Mr. Norman R. Bates
Chief Financial Officer
Jordan Industries, Inc.
Arbor Lake Center, Suite 550
1751 Lake Cook Road
Deerfield, Illinois 60015

	RE: 	Jordan Industries, Inc.
		Form 10-K for the fiscal year ended December 31, 2004
		Filed March 24, 2005
		Forms 10-Q for the quarters ended March 31, June 30, and
        September 30, 2005
		File No. 033-24317

Dear Mr. Bates:

      We have reviewed your response letter dated September 23,
2005
and filings and have the following comments.  Where indicated, we
think you should revise your documents in response to these
comments.
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 information so we may better
understand your disclosure.  After reviewing this information, we
may
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
filings.
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.

Forms 10-Q for the Quarters Ended March 31, and June 30, 2005

1. We note that you have not furnished the Exhibit 32
certifications
in your Forms 10-Q for the quarters ended March 31, and June 30,
2005.  Please amend your filings to furnish these exhibits or tell
us
why you are not required to furnish these certifications.  Please
refer to Rule 15d-14 of the Securities Exchange Act and Section
III.B
of Management`s Reports on Internal Control Over Financial
Reporting
and Certification of Disclosure in Exchange Act Periodic Reports,
SEC
Release No. 33-8238.

Form 10-Q for the Quarter Ended September 30, 2005

Financial Information, page 3

Note M. Affiliate Transactions, page 10

2. We note from page 11 that you recorded $7,966,000 in operating
income during the third quarter of 2005 as a result of receiving
$15
million in fees and repayments from a refinancing transaction
related
to Healthcare Products Industries, Inc.  Please respond to the
following comments:

* Please tell us and disclose in future filings the significant
terms
of the refinancing transaction and how you accounted for and
measured
the related gain of $7,966,000.
* Please tell us why you classified the gain within operating
income.
* Please tell us the accounting literature upon which you relied
and
explain how you applied that literature to this transaction.
* Please tell us how you define the term "affiliate" as used in
Note
M.  That is, discuss whether these transactions relate to
investments
accounted for under the equity method or to companies that are
consolidated.  If the "affiliates" are consolidated companies that
are not majority owned, then please tell us the basis for their
consolidation under U.S. GAAP.
* Please revise MD&A in future filings to discuss the nature and
timing of this gain and its impact on your results of operations
and
cash flows.

	As appropriate, please amend your March 31, and June 30, 2005
Forms 10-Q 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 amendments to expedite our
review.  Please furnish a cover letter with your amendments that
keys
your responses to our comments and provides any requested
information.  Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your responses to our comments.

	You may contact Eric Atallah, Staff Accountant at (202) 551-
3663
or me at (202) 551-3604 regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Angela Crane, Branch Chief, at (202) 551-3554.

      								Sincerely,

								Kate Tillan
								Assistant Chief Accountant

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Mr. Norman R. Bates
Jordan Industries, Inc.
November 17, 2005
Page 3

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