SecProbe.io

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      Mail Stop 7010
      July 12, 2005

By U.S. Mail and Facsimile

Mr. Thomas J. Koenig
Vice President and Chief Financial Officer
Day International Group, Inc.
130 West Second Street
Dayton, Ohio 45402

Re:	Day International Group, Inc.
	Form 10-K for the Fiscal Year Ended December 31, 2004
	Form 10-Q for the Fiscal Quarter Ended March 31, 2005
      	File No.  033-93644

Dear Mr. Koenig:

      We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise your document 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 filing.
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.

Form 10-K for the Fiscal Year Ended December 31, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 14

Contractual Obligations, page 23

1. We note that long-term debt represents the majority of your
contractual obligations as of December 31, 2004.  In future
filings,
please expand the table to address, or provide a footnote
disclosure
to the table of contractual obligations, of your obligations in
respect of interest payments associated with these long-term debt
maturities.

Item 9A. Controls and Procedures, page 59

2. We note your disclosure that "management, with the
participation
of the Company`s Chief Executive Officer and Chief Financial
Officer,
assesses the internal control and disclosure control systems as
being
effective as they encompass material matters for the three months
ended December 31, 2004."  Please confirm to us and revise future
annual and quarterly filings to state, in clear and unqualified
language, that your disclosure controls and procedures were
effective, or not effective, as of the end of the annual or
quarterly
period covered by the report.  See Exchange Act Rule 13a-15(e) for
guidance.

Form 10-Q for the Fiscal Quarter Ended March 31, 2005

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 17

Liquidity and Capital Resources, page 19

3. To enhance your disclosure, please confirm and revise future
filings to disclose whether you are in compliance with the
covenants
contained in your applicable debt agreements as of the latest
balance
sheet date.  To the extent material, disclose and discuss your
most
restrictive debt covenants.

*	*	*

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

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 their filings;
* 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.

     If you have any questions regarding these comments, you may
contact Dale Welcome, Staff Accountant, at (202) 551-3865, John
Hartz, Senior Assistant Chief Accountant, at (202) 551-3689 or, in
their absence, to the undersigned at (202) 551-3768.

      Sincerely,

      John Cash
								Accounting Branch Chief
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Mr. Thomas J. Koenig
Day International Group, Inc.
July 12, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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