Mail Stop 0407

      							April 8, 2005

Via U.S. Mail and Fax
Mr. Jeffrey L. Wright
Senior Vice President and Chief Financial Officer
G&K Services, Inc.
5995 Opus Parkway
Minnetonka, MN  55343


	RE:	G&K Services, Inc.
      Form 10-K for the fiscal year ended July 3, 2004
		Filed September 16, 2004
		File No. 0-04063

Dear Mr. Wright:

	We have reviewed your letter dated January 31, 2005 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 supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

Form 10-K for the fiscal year ending July 3, 2004

Note 2.  Acquisitions, page F-10

1. Based on your response to comment 7, it appears that you
believe
your industry is consolidating to several large providers from
many
family owned and small local providers.  In future filings, revise
your discussions within the Business section and also Management`s
Discussion and Analysis to give the reader your view on the
Company`s
plans for future acquisitions as well as consolidation within the
industry.  Because you discuss these acquisitions and the
projected
impact on your revenue in news releases to the general public, it
would appear that this information would be meaningful in your
Form
10-K.

2. We note your response to comment 8.  While it appears that the
recent acquisitions are not material to your total assets or net
income from a pro forma standpoint, we note that the goodwill
balances are material when compared to total assets, and the
recent
acquisition of Lion Uniform Group will materially increase your
direct sale business.  Additionally, since the cash outflows have
been a material use of cash for investing activities in all
periods
since June 29, 2002, and in certain periods exceed the total cash
provided by operating activities, we believe additional disclosure
is
necessary.  To the extent that you issue press releases on these
acquisitions, we believe you should be discussing them in your
MD&A
at a minimum  Please provide additional disclosure in accordance
with
paragraph 53 of SFAS 141.


Note 3.  Goodwill and Intangible Assets, page F-10

3. We note your response to comment 9.  We also note in your
response
to comment 1 that the businesses that you have acquired are
primarily
family owned, small local providers of rental services to small
and
medium sized customers.  In light of the nature of your
acquisitions
and the apparent geographically discrete nature of the Company`s
operations, it is unclear to us why management has not identified
components of the Company`s operating segments as reporting units
in
accordance with the guidance in paragraph 30 of SFAS 142.  Please
provide us a detailed explanation of your full consideration of
the
relevant GAAP literature, including the guidance in EITF D-101.
Describe in your response the Company`s operations and
organization
and explain how they relate to the literature.

4. In future filings, expand your disclosure relating to your
annual
impairment testing under SFAS 142 in a manner consistent with your
response to comment 10.

      *    *    *    *


      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
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 file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your responses to our
comments.



      You may contact Kathleen Kerrigan, Staff Accountant, at
(202)
942-1944 or Robert S. Littlepage, Accountant Branch Chief, at
(202)
942-1947 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 942-
1990
with any other questions.




							Sincerely,



							Larry Spirgel
							Assistant Director
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Mr. Jeffrey L. Wright
G&K Services, Inc.
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