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DAY INTERNATIONAL, INC.          CORRESPONDENCE

    130 W. Second St.

P.O. Box 338

Dayton, OH 45401-0338

(937) 224-7124

Fax (937) 226-1855

DAY INTERNATIONAL, INC.

July 28, 2005

Mr. Dale Welcome

Staff Accountant

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-7010

    RE:

    Securities and Exchange Commission Comment Letter dated

    July 12, 2005 concerning:

    Day International, Inc.

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

    Form 10-Q for the period ended March 31, 2005

Dear Mr. Welcome:

Day International, Inc. (“Day” or the “Company”) has carefully reviewed the comments contained in
your letter to the Company dated July 12, 2005 (the “Comment Letter”). The following are our
responses:

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

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Contractual Obligations, page 23

1.      Comment — Long-term debt represents the majority of 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 interest obligations associated with these long-term debt
maturities.

1.      Response — In future filings, the Company will disclose interest obligations associated with
the long-term debt obligation for each period shown in the table. In 2004, interest expense on
long-term debt was $21,985.

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

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Item 9A. Controls and Procedures, page 59

2.      Comment — 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.

2.      Response — The Company has established disclosure controls and procedures to ensure that
material information relating to the Company is made known to the officers who certify the
Company’s financial reports and to other members of senior management and the Board of Directors.
Management, with the participation of the Company’s Chief Executive Officer and Chief Financial
Officer, evaluated the effectiveness of the Company’s disclosure controls and procedures as of the
end of the period covered by the Company’s Form 10K for the fiscal year ended December 31, 2004 and
Form 10Q for the quarter ended March 31, 2005 and, based on that evaluation, concluded that as of
December 31, 2004 and March 31, 2005 the Company’s disclosure controls and procedures were
effective to ensure that the information required to be disclosed by the Company in the reports
that it files or submits under the Securities Exchange Act of 1934 is recorded, processed,
summarized and reported within the time periods specified in the Securities Exchange Commission’s
rules and forms. Future annual and quarterly filings we be revised to include the above
disclosure.

Form 10-Q for the fiscal quarter ended March 31, 2005

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Liquidity and Capital Resources, page 19

3.      Comment — Confirm and revise future filings to disclose whether the Company is in compliance
with the covenants contained in applicable debt agreements as of the latest balance sheet date. To
the extent material, disclose and discuss the most restrictive debt covenants.

3.      Response — The Company’s debt agreements contain certain financial covenants regarding a
consolidated leverage ratio, a consolidated senior debt ratio, a consolidated interest coverage
ratio, a consolidated fixed charge coverage ratio, and a limitation on capital expenditures. As of
March 31, 2005, the Company remained in compliance with all debt covenants and none of the
covenants were materially restrictive. The Company will disclose and discuss, if material, the
most restrictive debt covenants in future filings.

The Company acknowledges that it is responsible for the adequacy and accuracy of the disclosure in
its filings, that SEC staff comments or changes to disclosure in response to SEC staff comments do
not foreclose the SEC from taking any action with respect to the filing, and that the Company may
not assert SEC staff comments as a defense in any proceeding initiated by the SEC or any person
under the federal securities laws of the United States.

If you have any questions, please contact me. My direct dial number is (937) 222-5714.

Sincerely,

Thomas J. Koenig

Vice President and CFO

Day International, Inc.