SecProbe.io

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Mail Stop 0510

March 17, 2005

via U.S. mail and facsimile

Mr. M. David Kornblatt
Vice President and Chief Financial Officer
York International Corporation
631 South Richland Avenue
York, Pennsylvania  17403

	RE:	York International Corporation
		Form 10-K for the fiscal year ended December 31, 2004
		Filed March 14, 2005

		File No. 1-10863

Dear Mr. Kornblatt:

      We have limited our review of the above referenced filings
to
your asbestos-related claims disclosures.  Other than as
discussed,
no further review of your periodic reports has been or will be
made.

      Where indicated, we think you should revise future filings
to
comply with our comment.  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.

	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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended December 31, 2004

Note 13 - Commitments and Contingencies, Asbestos-related
litigation

1. We have the following comments regarding your asbestos-related
claims with and without insurance/indemnification coverage
disclosures.  We note that you have concluded that the reasonably
possible loss in excess of accrual for all of your asbestos-
related
claims is immaterial; however, we request that you consider
addressing the following disclosure items in your next periodic
filing.  Please note that when your reasonably possible loss in
excess of accrual becomes material to your consolidated financial
statements, these disclosure items are required to be provided.
* Please provide a full description of the actions being sought by
the declaratory judgment action by one of your insurance carriers.
Specifically:
o Disclose the fact that the insurance carrier is seeking to
nullify
any recovery by you related to these claims.
o Provide more detail regarding the implications of the insurance
carrier seeking declaration that all of the underlying asbestos
claims constitute a single occurrence, which would then limit
recovery to the occurrence limits instead of the aggregate limits.
Also, clarify for a reader where York currently stands in terms of
meeting the occurrence limit.
o Disclose that the insurance carrier is seeking to limit the
occurrence limit to the policy period instead of each annual
period
and the implications of such change.
o Disclose the "pro rata" versus "joint and several" issue and the
implications thereof.
* State the amount of loss contingency accrued and recoveries
recorded for each period presented, not just the current period.
* Provide a further break down of claims disposed between claims
dismissed and claims settled to provide more meaning to settlement
cost disclosure.
* State the average settlement amount of claims settled during
each
period presented by the insurance companies and yourself.
* For the asbestos-related claims you do not have indemnifications
or
insurance coverage, provide a separate rollforward of the claims
and
the average settlement amounts for each period presented.

*    *    *    *

      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comment
and
provides any requested supplemental information.  Detailed
response
letters greatly facilitate our review.  Please file your response
letter on EDGAR.  Please understand that we may have additional
comments after reviewing your response to our comment.

	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 Tracey Houser, Staff Accountant, at (202)
942-
1989, Jeanne Baker at (202) 942-1835 or me at (202) 942-1798 if
you
have questions regarding comments on the financial statements and
related matters.

							Sincerely,

							John Hartz
							Senior Assistant Chief
Accountant

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Mr. Kornblatt
York International Corporation
March 17, 2005
Page 1 of 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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