SecProbe.io

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Mail Stop 0510

      March 28, 2005

via U.S. mail and facsimile

Mr. John C. Tough
Vice President Finance and Chief Financial Officer
Anchor Lamina Inc.
Province of Ontario, Canada
2590 Ouellette Avenue, Windsor, Ontario N8X 1L7

	RE: Form 20-F for the fiscal year ended August 31, 2004
	       File No. 333-8426

Dear Mr. Tough:

		We have reviewed these filings and have the following
comments.  If you disagree with a comment, 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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM 20-F FOR THE FISCAL YEAR ENDED AUGUST 31, 2004

Comment applicable to your overall filing
1. Where a comment below requests additional disclosures or other
revisions, please show us in your supplemental response what the
revisions will look like.  These revisions should be included in
your
future filings.

Selected Financial Data, page 3

2. Please revise selected financial data or Note 17 to provide a
reconciliation of operating income determined in accordance with
Canadian GAAP and operating income determined in accordance with
US
GAAP.  Please refer to instruction 2 to Item 3A of Form 20-F.

Operating and Financial Review and Prospects, page 19

3. Please enhance your operating and financial review and
prospects
disclosures as follows:
* Quantify your explanations for significant changes in product
sales
and cost of sales in terms of increases or decreases in prices,
volume and foreign currency and include an explanation of the
underlying reasons for the changes.
* Quantify your explanations for the changes in sales and cost of
sales of your steel cutting, grinding and machining services in
terms
of increases or decreases in prices, volume and foreign currency.
* Describe any variation in pricing in relation to the variation
in
the price of steel in global commodity markets and indicate
whether
recent price increases are viewed as sustainable.
* Discuss the dollar and percentage impact of any raw material
surcharges on product sales.
* Quantify the impact of operating efficiencies arising from
capital
expenditures on your profitability.

4. Please disclose and discuss the full year effect of your change
in
accounting estimate for the useful lives of machinery and
equipment
on gross profit and operating income in 2004 and 2003.

5. Please disclose the critical accounting policies that require
significant estimates and judgments.  Please indicate whether you
have discussed your critical accounting estimates with your audit
committee.  Additionally, for each critical accounting policy or
estimate, please discuss the likelihood of materially different
reported results if different assumptions or conditions were to
prevail.  To the extent practicable and meaningful, you should
also
quantify the effect changes in assumptions and estimates would
have
on your overall financial performance.  Please refer to SEC
Releases
33-8040 and 33-8098.

Liquidity and Capital Resources, page 24

6. Please disclose the terms of your financial covenants as well
as
any cross default provisions in your bank credit facility.  Please
discuss the impact on your liquidity of the $2,396,000 in
accelerated
loan payments due on your credit facilities by December 5, 2004.
Please also discuss that all term loans and credit facilities
expire
on November 14, 2005 as well as your plans for refinancing this
debt.
Please also discuss the impact on your liquidity from the proposed
redemption of the subordinated notes.  Please also discuss any
projected payments arising from your environmental exposures.

Tabular Disclosure of Contractual Obligations, page 26

7. Please revise your table of contractual cash obligations to
include estimated interest payments on your debt.  Because the
table
is aimed at increasing transparency of cash flow, we believe these
payments should be included in the table.  Please also disclose
any
assumptions you made to derive these amounts.  Please refer to
footnote 46 of SEC Release 33-8350.

Financial Statements

Report of Independent Registered Chartered Accountants, page 1 of
24

8. Please revise to include a signed audit report.

Consolidated Statements of Cash Flows, page 6 of 24

9. Please tell us if the subtotal before net change in non-cash
working capital is expressly permitted under Canadian GAAP.  If
so,
please also provide us with an excerpt of the relevant Canadian
accounting literature.

10. Please supplementally tell us about the items and the
respective
amounts that comprise the net change in non-cash working capital.

Note 1 - Significant Accounting Policies, page 7 of 24

11. Please disclose net sales of products and revenues from
services.
Please also disclose the cost of product sales and the cost of
tolling services.  Refer to Item 17(b) of Form 20-F and Rule 5-
03(b)(1) and (2) of Regulation S-X.

12. Please discuss your accounting policy for establishing
reserves
for doubtful accounts as well as the typical credit terms for your
commercial accounts.

Note 17 (d) - United States Accounting Principles, page 21 of 24

13. Please disclose the cost flow assumption used to value your
inventory.

14. Please disclose your revenue recognition policy for cutting,
grinding and machining services.  Please refer to SAB Topic 13:A.

15. Please disclose the status of your environmental testing and
whether it could have a material adverse effect on your financial
position, results of operations and cash flows.  Please provide
the
disclosures required by SFAS 5, including paragraph 10, and SAB
Topic
5:Y.

16. Please disclose the method and the assumptions used to
determine
the fair value of the subordinated notes in accordance with
paragraphs 10 and 11 of SFAS 107.

Schedule II - Valuation and Qualifying Accounts

17. Please disclose the activity in reserve accounts for bad debt
allowances as required by Schedule II - Valuation and Qualifying
Accounts of Regulation S-X.

*    *    *    *

      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 supplemental response letter that keys your responses to
our
comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental 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 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 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, please
direct them to Gus Rodriguez, Staff Accountant, at (202) 824-5524
or,
in his absence, Scott Watkinson, Staff Accountant, at (202) 942-
2926
or, to the undersigned, at (202) 942-1774.

    						Sincerely,

							Rufus Decker
							Branch Chief
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Mr. John C. Tough
March 28, 2005
Page 1 of 5

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

         DIVISION OF
CORPORATION FINANCE

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