EXHIBIT 16.1





Office of the Chief Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549



June 18, 2002

Dear Sir or Madam:

The representations made in this letter are based solely on discussions with and
representations from the engagement partner and manager on the audits of the
consolidated financial statements of this registrant for the two most recent
fiscal years. Those individuals are no longer with Arthur Andersen LLP. We have
read Item 4 included in the Form 8-K dated June 18, 2002 of Cole National
Corporation to be filed with the Securities and Exchange Commission and have
found no basis for disagreement with the statements contained therein.


Very truly yours,

ARTHUR ANDERSEN LLP


By: /s/ Arthur Andersen LLP
    -----------------------



cc: Mr. Thomas T. S. Kaung