SecProbe.io

July 8, 2005

Via US Mail and Facsimile

Scott A. Deininger
Senior Vice President of Finance and Administration
American Tire Distributors Holdings, Inc.
12200 Herbert Wayne Court, Suite 150
Huntersville, North Carolina 28078

Re: American Tire Distributors, Inc.
 Form 10-K for the year ended January 1, 2005
 Commission File Number:  333-61713

 American Tire Distributors Holdings, Inc.
Form S-4 filed May 12, 2005
Form 10-Q for the period ended April 2, 2005
 Commission File Number: 333-124878

Dear Mr. Deininger:

We have reviewed your amended Form S-4 and have the following comments.  Where
indicated, we think you should re vise 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  supplemental information so we may better
understand your disclosure.  After reviewing th is information, we may or may not raise
additional comments.

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 filings.  We look forward
to working with you in these respects and 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.

  As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with ma rked 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 supplemen tal information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may ha ve additional comments after

Mr. Scott D eininge r
American Tire Distributors Holdings, Inc.
July 8, 2005
Page 2

reviewing your amendment and responses to our comments.

* * * * * * * * * * *

Summary Consolidated Fi nancial Data, page 16

1. Certain of the successor company balances as  of, and for the period ended April 2, 2005 do
not appear to be correctly stated.  We refer,  for example, to redeemable preferred stock,
shareholders’ equity, and to the various component s of “Other Financial Data.”  Please revise
or advise.  This comment applies to the ba lances presented on pa ges 55 and 56, as well.

* * * * * * * * * * *

As appropriate, please amend the 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 urge all persons who are responsible for th e 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 comp any and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.

Notwithstanding our comments, in the event the company requests acceleration of the
effective date of the pending registration statement,  it should furnish a letter, at the time of such
request, acknowledging that

• Should the Commission or the st aff, acting pursuant to delegated authority, declare
the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;
• The action of the Commission or  the staff, acting pursuant to delegated authority in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of th e disclosure in the filing; and
• The company may not assert this action as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divisi on of Corporation Finance in connection with
our review of your filing or in re sponse to our comments on your filing.

Mr. Scott D eininge r
American Tire Distributors Holdings, Inc.
July 8, 2005
Page 3

We will consider a written request for acceleration of the effective date of the registration
statement as a confirmation of the fact that those requesting accelerat ion are aware of their
respective responsibilitie s under the Securities Act of 1933 and the Securities Exchange Act of
1934 as they relate to the proposed public offeri ng of the securities specified in the above
registration statement.  We w ill act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

We direct your attention to  Rules 460 and 461 regarding requesting acceleration of a
registration statement.  Please a llow adequate time after the fili ng 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.

 You may contact Amy Geddes,  Staff Accountant at 202- 551-3304 or Margery Reich,
Review Accountant at 202-551-3347 if you have  questions or me at 202-551-3211 with any
concerns as I supervised the review of your filing.

        S i n c e r e l y ,

        David R. Humphrey
        B r a n c h  C h i e f