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CORRESP
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corresp

American Commercial Lines Inc.

1701 East Market Street

Jeffersonville, Indiana 47130

October 4, 2005

VIA FACSIMILE AND EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    American Commercial Lines Inc.

Registration Statement on Form S-1 (File No. 333-126696), as amended

     Ladies and Gentlemen:

     Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, American
Commercial Lines Inc., a Delaware corporation (the “Company”), hereby requests that the
effectiveness of the above-referenced Registration Statement (the “Registration Statement”)
be accelerated so that the Registration Statement will become effective at 3:00 p.m., Washington,
D.C. time, or as soon thereafter as practicable, on October 6, 2005.

     The undersigned hereby acknowledges on behalf of the Company that as of the date hereof:

    •

    should the Securities and Exchange Commission (the “Commission”) or the
staff, acting pursuant to delegated authority, declare the Registration Statement
effective, it does not foreclose the Commission from taking any action with respect to
the Registration Statement;

    •

    the action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the Registration Statement effective, does not relieve the Company from
its full responsibility for the adequacy and accuracy of the disclosure in the
Registration Statement; and

    •

    the Company may not assert this action as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

    Very truly yours,

AMERICAN COMMERCIAL LINES INC.

    By:
    /s/ Lisa L. Fleming

    Lisa L. Fleming

    Senior Vice President, Law & Administration