Mail Stop 03-05

      January 11, 2005
Mr. Walter L. Bennett
Chief Financial Officer
Thor Industries, Inc.
419 W. Pike Street
Jackson Center, OH 45334

      Re: Thor Industries, Inc.
             File No. 001-09235
             Form 10-K for the year ended July 31, 2004
             Form 10-K/A Amendment No. 1 for the year ended July
31,
2004

Dear Mr. Bennett:

	We have reviewed your response letter dated December 8, 2004
and
have the following additional comments. Where indicated, we think
you
should revise your document in response to these comments in
future
filings. 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. Please be as detailed
as
necessary in your explanation. We look forward to working with you
in
these respects and welcome any questions you may have about any
aspects of our review.

Refer to prior comment 1
1. Please explain the reason for the increase in demand for motor
homes and tell us whether you expect this higher level of demand
to
continue.  Provide a detailed analysis of the factors that
contributed to the increase.  In addition, explain the reason for
the
increase in sales of new diesel motor homes.  Finally, explain the
reason for the overall industry market increase in recreational
vehicles.  Revise future filings to discuss these factors.








Refer to prior comment 7
2. Please provide an analysis that supports your conclusion that
Thor
Credit was not designed so that substantially all of its
activities
either involve or are conducted on behalf of Thor Industries or
its
related parties.  As part of your response, quantify the
percentage
of Thor Credit`s financing activities that relate to Thor
Industries`
consumer buyers and explain how you have considered this factor in
your analysis.

* * * * *

      Please file your response to our comments via EDGAR within
ten
business days from the date of this letter.  Please understand
that
we may have additional comments after reviewing your response.
You
may contact Patrick Kuhn at 202-824-5330 or the undersigned at
202-
942-1907 with any questions.

								Sincerely,


								Michael Fay
								Branch Chief


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Mr. Walter L. Bennett
Thor Industries, Inc.
January 11, 2005
Page 1