May 16,  2006

Mail Stop 7010

via U.S. mail and facsimile

Mr. Stephen T. Auburn
Vice President, General Counsel
   and Secretary
Pliant Corporation
1475 Woodfield Road, Suite 700
Schaumburg, IL     60173

RE:	Pliant Corporation
	Form T-3
	Filed on:  April 26, 2006
	File No.:  22-28809

Dear Mr. Auburn:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise 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 information so we
may
better understand your disclosure.  After reviewing this
information,
we may 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 any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

Item 2. Securities Act exemption applicable, page 2
1. We note that the Bankruptcy Court has not approved the
Applicant`s
plan of reorganization and is not expected to do so until June,
2006.
Please note that we reserve the right to provide additional
comments
on the Form T-3, including exhibits at any time, whether in
connection
with your response to this letter or otherwise.


Principal owners of voting securities, page 4
2. The information presented in this section should be updated to
a
date within 31 days as required by Item 5 of Form T-3.
3. Identify the person(s) who exercise sole or shared voting
and/or
investment power with respect to the shares shown for the
Christena
Karen H. Durham Trust.  Identify the beneficial owners of the
trust.

      As appropriate, please amend your Form T-3 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 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 the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Trust Indenture Act of
1939 and that they have provided all information investors require
for
an informed investment 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
disclosure
they have made.

      Notwithstanding our comments, in the even the company
requests
acceleration of the effective date of the pending Form T-3, it
should
furnish a letter, at the time of such request, acknowledging that:

* should the Commission or the staff, 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 the disclosure in the filing; and

* the company may not assert staff comments and the declaration of
effectiveness 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 connection with our review of your
filing or
in response to our comments on your filing.


	We will consider a written request for acceleration of the
effective date of the Form T-3 as confirmation of the fact that
those
requesting acceleration are aware of their respective
responsibilities
under the Trust Indenture Act of 1939 as they relate to the
proposed
public offering of the securities specified in the above Form T-3.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	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.

	Please contact Dorine H. Miller, Financial Analyst at (202)
551-
3711 or me at (202) 551-3760 with any other questions.

Sincerely,



Pamela A. Long
Assistant Director

Mr. Stephen T. Auburn
Pliant Corporation
May 16, 2006
Page 3



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

         DIVISION OF
CORPORATION FINANCE