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                               KRYS BOYLE, P.C.
                               Attorneys at Law
Telephone                   Suite 2700 South Tower                 Facsimile
(303) 893-2300              600 Seventeenth Street            (303) 893-2882
                          Denver, Colorado 80202-5427

                                August 9, 2005

John Reynolds, Assistant Director
Office of Emerging Growth Companies
United States Securities and Exchange Commission
100 F Street, NE, Mail Stop 3561
Washington, D.C.  20549

     Re:  American TonerServ Corp.
          Amendment No. 3 to Registration Statement on Form SB-2
          File No. 333-120688

Dear Mr. Reynolds:

     This letter will serve as a response and/or explanation with respect to
the comments in your letter dated August 5, 2005 (the "Comment Letter")
regarding American TonerServ Corp. ("American TonerServ" or the "Company").
The entire text of the comments contained in your comment letter has been
reproduced in this letter for ease of reference.  A response to each comment
is set forth immediately below the text of the comment.

Management's Discussion and Analysis, page 9
--------------------------------------------

     Overview
     --------

     1.  We note that as of December 31, 2004, you are the primary obligor
with 41 companies and have $303,000 of contracts in force.  Please update
this information to the latest practicable date.

     We have updated the information to June 30, 2005, which is the latest
     practicable date that this amount can be calculated.

     Results of Operations:  Comparison of Years Ended December 31
     -------------------------------------------------------------

     2.  In prior comment 12 dated July 8, 2005, we asked that you explain
why toner revenue is down.  The revised disclosure suggests the reason is
because of sales staff reductions and turnover.  Please elaborate on these
reductions, the reasons for them and how you plan to address the reductions.
If these reductions, or the reasons behind them, represent a material risk,
consider addressing in a risk factor.  Provide similar disclosure under
Comparison of Three Months Ended March 31.

     We have revised the referenced disclosures and added disclosures
     concerning the sales staff reductions and the effect on toner
     revenue in response to this comment.

Page 2

     Liquidity and Capital Resources
     -------------------------------

     3.  Please provide the basis for the following statement:  "The base of
service providers for our primary market of printers is still large and we
believe that we can increase this service base when we execute our business
strategy."

     We have revised the discussion about service providers to clarify
     that it is about the number of providers that would be available to
     us, and to disclose the basis for the statements made.  In the past,
     the Company has increased and decreased the number of active service
     providers based on the number of equipment service calls it receives
     from customers.  As the Company has shifted its business model and
     experienced a decrease in service revenues, the need for active service
     providers on a nationwide basis has diminished.  However, through
     communications with these service providers and actual working
     experience with them on service calls, the Company believes that most
     of the providers will continue to work with the Company when it
     implements its national remanufacture toner strategy.

     4.  Please provide your available cash balance as of the last
practicable date.

      We have updated the amount of cash available to July 31, 2005, as
      requested.

Certain Transactions, page 28
-----------------------------

     5.  We are unable to locate on Edgar the supplemental legal analysis
requested in prior comment 24 dated July 8, 2005.  Please file it on Edgar.

     The supplemental legal analysis was filed on EDGAR on August 5,
     2005, as requested.

Closing Comments
----------------

     As appropriate, please amend your registration statement in response to
these comments.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter with your
amendment that keys your responses to our comments and provides any requested
supplemental information.  Detailed cover letters greatly facilitate our
review.  Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.

     We direct your attention to Rules 460 and 461 regarding requesting
acceleration of a registration statement.  Please allow adequate time after
the filing of any amendment for further review before submitting a request
for acceleration.  Please provide this request at least two business days in
advance of the requested effective date.

Page 3

     The Company is submitting a request that the effectiveness of the
     registration statement be accelerated to Friday, August 12, 2005
     at 2:00 p.m., Eastern Daylight Time.

     Any questions regarding the financial statements may be directed to
Angela Halac at (202) 551-3398.  Questions on the other disclosure issues may
be directed to William Bennett at (202) 551-3389.

                    _______________________________________

     Please contact the undersigned if we can be of any additional assistance
in connection with your review of this matter

                                 Very truly yours,

                                 KRYS BOYLE, P.C.

                                 By: /s/ James P. Beck
                                     James P. Beck

cc:  American TonerServ Corp.

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