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Direct Dial: 972-695-1003

Direct Fax: 972-695-1022

E-Mail Address:kkrzeminski@homeinteriors.com

July 14, 2005

Mr. George F. Ohsiek, Jr., Branch Chief

United States Securities and Exchange Commission

Washington, D.C. 20549

    Re:

    Home Interiors & Gifts, Inc.

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

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

    File No. 333-62021

Mr. Ohsiek:

     We have reviewed your additional correspondence dated June 7, 2005 and considered our phone
conversations of June 20, 2005 and June 23, 2005, and offer you the following responses to your
inquires. For your convenience, we have numbered our responses to correspond with the order of
your inquiries, and have restated the text of each of your questions in italics within the body of
our response:

    1.

    Please advise if any state laws are applicable to your company in regard to
the repurchase and accounting treatment of your 12.5% Senior Convertible Preferred
Stock in fiscal 2004. Absent state law supporting your accounting treatment please
provide guidance that supports deducting dividends declared from additional paid in
capital if you have a net deficit.

    There are no known state laws that would impact the accounting treatment of the
Preferred Stock repurchase.

    On June 23, 2005, Brian Hermes, Senior Legal Counsel, and Karen Zambetti, Director of
Corporate Governance, had a telephone call with Adam Phippen, Staff Accountant for the
Securities and Exchange Commission. In that conversation, Mr. Phippen noted that after
researching the facts of this matter, they were not able to find any precedence with a
similar factual scenario. As a result, the SEC made the following proposal, based
solely on the facts at issue in this situation:

    •

    On the Consolidated Statement of Shareholder’ Deficit, found on page F-5 of
the 10-K for the fiscal year ended December 31, 2004, the SEC proposes that we
debit the Accumuluated Deficit column by the

    $45,103,000 entry that is currently presented in the APIC column and then add a
line to reclassify the amount from the Accumulated Deficit column to the APIC
column.

    •

    On Note 12, found on page F-21 of the 10-K for the fiscal year ended
December 31, 2004, the SEC proposes that we add another line item to the Net
income (loss) table applicable to common shareholders to further disclose that
the Net Income is less the premium paid for the preferred stock deductions.

    We will incorporate such comments into future filings.

    2.

    Tell us the covenant levels required as of March 31, 2005 and June 30, 2005
and the level achieved as of March 31, 2005. Tell us what specific covenants you are
in danger of violating.

    We will incorporate more prospective and detailed information regarding our covenant
levels in future filings, where appropriate.

     If you have any further questions, please do not hesitate to contact me at the above
referenced number.

    Sincerely,

    /s/ Keith S. Krzeminski

    Keith S. Krzeminski
Senior Vice President of Finance and CFO