Mail Stop 3561

      August 19, 2005

David G. Fiore
President and Chief Executive Officer
AAC Group Holding Corp.
7211 Circle S Road
Austin, Texas 78745

	Re:	AAC Group Holding Corp.
		Amendment No. 4 to Registration Statement on Form S-4
      Filed June 7, 2005
      Form 8-K
      Filed July 22, 2005
      File No. 333-121479

Dear Mr. Fiore:

      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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Consolidated Financial Statements and Notes to Consolidated
Financial
Statements

Note 17: Business Segments (Restated), page F-36

1. In your response to comment 1 in our letter dated June 22,
2005,
you state that the operating segments of On Campus Class Rings and
Retail Class Rings have been aggregated into one reportable
segment.
Please disclose that operating segments have been aggregated in
accordance with paragraph 26.a. of FAS 131.


Form 8-K filed July 22, 2005

2. It does not appear that you have included all of the
information
required by Item 5.02 of Form 8-K.  Please advise or revise.


*****

      As appropriate, please amend your filings 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 letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comment

      You may contact Dave Irving at (202) 551-3321 or Mike Moran,
Accounting Branch Chief, at (202) 551-3841 if you have questions
regarding comments on the financial statements and related
matters.
Please direct any other questions to Howard M. Baik at (202) 551-
3317
or to Ellie Quarles, Special Counsel, at (202) 551-3238.


      Sincerely,


      H. Christopher Owings
      Assistant Director

cc (via fax):  Joel F. Freedman, Esq.


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David G. Fiore
AAC Group Holding Corp.
August 19, 2005
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