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Correspondence

HOME SOLUTIONS OF AMERICA, INC

5565 Red Bird Center
  Drive

Dallas, Texas 75237

Via EDGAR

June 13, 2005

U.S. Securities and Exchange Commission

Division of
Corporation Finance

Attn: Ms. Rachel
Zablow, Staff Accountant

Washington, D.C. 20549

            Re:       Home
Solutions of America, Inc.

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

                        Filed
 March 28, 2005

                        File
No. 1-31711

Dear Ms. Zablow:

This letter provides the response of Home Solutions of
America, Inc. (the "Company") to the comment letter received from the
Commission on May 31, 2005.

SEC Comment

	With respect to your SE and FSS acquisitions, we note
that a significant portion of the purchase price is allocated to goodwill.
Please advise us of your consideration of paragraphs 39 and A14 of SFAS 141 as
it relates to the recognition of intangible assets apart from goodwill and
advise us of any intangible assets included in goodwill that do not meet the
criteria for recognition apart from goodwill.

Company's Response

            Paragraph 39 of SFAS 141 states that an
intangible asset shall be recognized as an asset apart from goodwill if it
arises from contractual or other legal rights, or if it is separable from the
acquired business.  Paragraph A14 of SFAS 141 provides several examples of
intangible assets that meet the criteria for recognition apart from goodwill.
In order to respond to the Staff's comment regarding the Company's
consideration of paragraphs 39 and A14, it is necessary to outline the steps
that the Company took in arriving at the purchase accounting for the
acquisitions of SE and FSS:

1.         The Company calculated the price paid for
SE and FSS, including cash and non-cash consideration paid for these companies;

2.         The Company conducted an independent
appraisal of the tangible assets of SE and FSS, to determine the fair market
values of such assets;

3.         The purchase price less the fair market
value of the net tangible assets was assigned to goodwill;

(214) 623-8446 main (214)
333-9435 fax

www.HSOACorp.com

U.S. Securities and Exchange Commission

Division of
Corporation Finance

June 13, 2005

Page 2

4.         The independent appraisal firm retained by
the Company (discussed in 2. above) reviewed the contracts and operations of
FSS and SE with the Company's accounting personnel, to determine whether any portion
of the goodwill was comprised of intangible assets that should be recognized
apart from goodwill.  As a result of such review, no intangible assets of FSS
and SE were identified at all, therefore there were no intangible assets that required
recognition apart from goodwill.

5.         As part of the post-acquisition stand-alone
audits of SE and the year-end audit of the Company, the Company's auditors reviewed
the Company's review of the goodwill account (described in 4. above), to verify
that, under SFAS 141, no intangible assets should be recognized apart from
goodwill.  Again, no intangible assets were identified.

            Conclusion:  The Company's
accounting personnel have thoroughly reviewed the goodwill amounts resulting
from the acquisitions of FSS and SE with an independent valuation firm and the
Company's auditors, and have not identified any intangible assets, including
any intangible assets that would require recognition apart from goodwill under
SFAS 141.

Representations of the Company:  The Company hereby acknowledges that:

	the Company is responsible for the
adequacy and accuracy of the disclosure in the filings;

	Staff comments or changes to
disclosure in response to Staff comments do not foreclose the Commissions from
taking any action with respect to the filings; 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.

Respectfully
submitted,

HOME
SOLUTIONS OF AMERICA, INC.

By: /s/ RICK
J. O'BRIEN

            Rick
J. O'Brien

            Chief Financial Officer

cc:       J.
Paul Caver, Esq. - The Caver Law Firm