SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 3561

									October 20, 2005

Mr. Marcello Bottoli
President and Chief Executive Officer
Samsonite Corporation
11200 East 45th Avenue
Denver, CO 80239

      Re:	Samsonite Corporation
      Form 10-K for the Fiscal Year Ended January 31, 2005
      Filed April 29, 2005
      Form 8-K filed June 8, 2005
      File No. 0-23214

Dear Mr. Bottoli:

	We have reviewed your response letter filed on October 4,
2005
to our comment letter dated September 12, 2005 and have the
following
comments.  Please provide a written response to our comments.
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.

Form 10-K for the Fiscal Year Ended January 31, 2005

Critical Accounting Policies, page 27

1. We have reviewed your response to comment 5 in our letter dated
September 12, 2005 and continue to believe that you should discuss
the $3.9 million inventory obsolescence charge within the notes to
your financial statements.  Although the charge did not
significantly
impact gross margin percentage, the charge was material to your
net
loss for the year ended January 31, 2005.  Please confirm that you
will disclose the amount of and circumstances surrounding this
charge
and any other similar material one-time charges in the notes to
your
financial statements.

(1) Summary of Significant Accounting Policies, page F-7

2. We have reviewed your response to comment 6 in our letter dated
September 12, 2005.  Given the factors you identified to conclude
that gross presentation was more appropriate for your "shop-in-
shop"
sales, please tell us the basis for initially recognizing these
revenues on a net basis.  Please also tell us whether there were
any
changes in your "shop-in-shop" arrangements that prompted the
accounting change.  If the reclassification was akin to a
correction
of an error, please confirm as such in your response.
3. We have reviewed your response to comment 8 in our letter dated
September 12, 2005, noting that you exclude freight-out from cost
of
goods sold.  Please disclose your policy for classifying shipping
and
handling costs in the statements of operations.  If shipping and
handling costs are significant and are not classified in cost of
goods sold, disclose the amount of these costs and the line
item(s)
that include them.  See EITF 00-10.  In your response, please
quantify the amounts of warehousing and freight-out expenses
included
in selling, general and administrative expenses for each of the
historical periods presented.
(2) Refinancing, Recapitalization and Convertible Preferred Stock,
page F-11

4. We have reviewed your response to comment 11 in our letter
dated
September 12, 2005, noting that the total value of the
consideration
given up was substantially less than the carrying value of the 13
7/8% redeemable preferred stock.  Please tell us the circumstances
that led to the exchange transaction and the reasons why the
holders
of the 13 7/8% preferred shares agreed to accept consideration
considerably below the carrying value of their shares.  Also tell
us
in detail how you determined that May 1, 2003, as opposed to the
July
31, 2003 closing date, was the commitment date for all of your
convertible preferred stock issuances, as discussed in Issues 4
and 5
in EITF 00-27.  In this connection, we note that the market price
of
your common stock increased $0.27/share between May 1, 2003 and
July
31, 2003 and that you had not reached enforceable agreements with
all
involved parties as of May 1, 2003.  It appears a beneficial
conversion feature would have been applicable had you used a July
31,
2003 commitment date.
(16) Other Income (Expense) - Net, page F-28

5. We have reviewed your response to comment 16 in our letter
dated
September 12, 2005 and do not believe you have adequately
supported
your position that foreign currency transaction gains and losses
are
properly excluded from operating income.  Absent compelling
evidence
that income and losses on your foreign currency transactions are
unrelated to transactions made during the ordinary course of your
operations, we believe that the gains and losses should be
classified
in operating income.  Please tell us whether the underlying
transactions which generate your foreign currency transaction
gains
and losses are transactions entered during the ordinary course of
your operations, for example, in buying and selling products.  If
you
continue to believe that your current income statement
classification
is appropriate, please advise us in detail as to the basis for
your
position.  Otherwise please tell us how you intend to revise your
filings.

Form 8-K filed June 8, 2005

6. We have reviewed your response to comment 19 in our letter
dated
September 12, 2005.  Please provide us with an example of the
reconciliation you intend to provide in future filings.  We do not
require that you populate the sample reconciliation with any
amounts.
A table that breaks out each potential line item will suffice.
Please ensure that each excluded item is shown as a separate line
item.

      Please respond to these comments 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 comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

      You may contact Andrew Blume (Staff Accountant) at (202)
551-
3254 if you have questions regarding the comments on the financial
statements and related matters.  Please contact me at (202) 551-
3716
with any other questions.

								Sincerely,

									William Choi
									Accounting Branch
Chief

Mr. Marcello Bottoli
Samsonite Corporation
October 20, 2005
Page 1

</TEXT>
</DOCUMENT>