Mail Stop 05-10

						June 10, 2005

via U.S. mail and Facsimile

Mary Beth Gustafsson
Senior Vice President, General Counsel and Secretary
American Standard Companies Inc.
One Centennial Avenue
P.O. Box 6820
Piscataway, New Jersey 08855-6820

	Re:	American Standard Inc.
Form S-4 filed May 12, 2005
File No. 333-124857

Form 10-K for Fiscal Year Ended December 31, 2004
Form 10-Q for Fiscal Quarter Ended March 31, 2005
File No. 001-11415

Dear Ms. Gustafsson:

      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
supplemental 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.

Form S-4 filed May 12, 2005

General

1. Please file all exhibits with your next amendment, or as soon
as
possible.  Understand that we will need adequate time to review
these
materials before accelerating effectiveness.

2. We note that the Company is registering the Exchange Notes in
reliance on the staff`s position enunciated in Exxon Capital
Holdings
Corporation (available April 13, 1989), Morgan Stanley & Co.
Incorporated (available June 5, 1991), and Shearman and Sterling
(available July 2, 1993).  Accordingly, with the next amendment
please provide a supplemental letter to the staff (1) stating that
the issuer is registering the exchange offer in reliance on the
staff`s position in such letters, and (2) including the statements
and representations substantially in the form set forth in the
Morgan
Stanley & Co. Incorporated and Shearman and Sterling letters.

3. We note that definitions you include on page i with regard to
American Standard, the issuer, and the guarantors.  Please revise
here, and throughout the prospectus, to make clear which entity to
which you are referring.  Currently, based on your definitions, in
some sections your disclosure appears to state that American
Standard
Companies Inc. issued the outstanding notes and other sections it
appears that American Standard Companies Inc. is a guarantor of
the
outstanding notes.

4. Please confirm that the expiration date will be included in the
final prospectus disseminated to security holders and filed
pursuant
to the applicable provisions of Rule 424.

5. As currently represented, the offer could be open for less than
20
full business days due to the 5:00 p.m. expiration time instead of
an
expiration time of midnight on what ultimately be the twentieth
business day following commencement.  See Question and Answer
Eight
in Exchange Act Release No. 16623 (March 5, 1980).  Please confirm
that the offer will be open at least through midnight on the
twentieth business day.  See Rule 14d-1(g)(3).

Incorporation of Certain Documents by Reference, page ii

6. Please include the file numbers.  See Rule 411(d) of Regulation
C.

7. We note your disclosure in the fourth bullet point.  Please
note
that you will need to update the information stated here to
specifically reference documents filed after the date you filed
this
document.  Although you appear to be relying on paragraph H.69
from
our 1997 Manual of Publicly Available Telephone Interpretations,
please note that you can only refrain from specifically
incorporating
documents filed prior to effectiveness if you refer to the initial
filing of the registration statement and you are not otherwise
required to file an amendment.  In this connection, please also
confirm to us that in the first prospectus used after
effectiveness
and filed under Rule 424(b), you will identify all Exchange Act
reports filed prior to effectiveness that you have not
specifically
incorporated.

Forward-Looking Statements, page iii

8. The safe harbor for forward-looking statements provided in the
Private Securities Litigation Reform Act of 1995 does not apply to
statements made in connection with a tender offer.  See Section
27A(b)(2)(c) of the Securities Act and Section 21E(b)(2)(c) of the
Exchange Act.  Therefore, please delete the reference to the safe
harbor or state explicitly that the safe harbor protections it
provides do not apply to statements made in connection with the
offer.

Industry and Market Data, page iv

9. We note your use of information from industry publications and
the
statement that "[a]lthough we believe that such sources are
reliable,
we do not guarantee the accuracy or completeness of this
information...".  While you may state that you have not
independently
verified the data, you may not disclaim responsibility for the
information you elect to include in your prospectus.  Please
revise.

The Exchange Offer, page 2

10. State the exemption relied upon, and the facts used to support
the exemption, to issue the old notes.  Please make a similar
revision on page 11.

Certain U.S. Federal Income Tax Consequences, page 4

11. Please revise to substitute material for certain in your
subheading.

12. Please delete "we believe" from your disclosure here.  We note
your disclosure on the cover page which states affirmatively that
the
exchange will not be a taxable event for U.S. federal income tax
purposes.

13. Please revise your statement "but you should consult your tax
advisor about the tax consequences of the exchange offer."  Note
holders should be able to rely on the tax consequences disclosed
in
your registration statement.  You may indicate that holders may
consult with their own tax advisors concerning their individual
circumstances, however.

The Exchange Notes, page 5

14. In the "Ranking" section, please discuss how the exchange
notes
will rank in comparison to the obligations of each guarantor.
15. What does "effectively" junior mean?  Please revise to
explain.

Selected Consolidated Financial Data, page 9

16. Your selected consolidated financial data presents total
segment
income, which outside the context of your SFAS 131 disclosure is a
non-GAAP financial measure.  Please expand your disclosure to
include
the following:
* a discussion which details why the presentation of total segment
income provides useful information to investors regarding your
financial condition and results of operations,
* a footnote stating total segment income may not be comparable to
those of other entities, as not all companies and analysts
calculate
this non-GAAP measure in the same manner.
Refer to SEC Release No. 33-8176 and Questions 19-21 of SEC FAQ
dated
June 13, 2003.

Expiration Date; Extensions; Amendment; Termination, page 13

17. We note your reservation of the right to amend the terms of
the
offer.  Please revise to indicate that, in the event of a material
change in the offer, including the waiver of a material condition,
you will extend the offer period if necessary so that at least
five
business days remain in the offer following notice of the material
change.

18. You reserve the right to "delay accepting any outstanding
note".
Clarify in what circumstances you will delay acceptance and
confirm
that any such delay will be consistent with Rule 14e-1(c).  For
example, if you are referring to the right to delay acceptance
only
due to an extension of the exchange offer, so state.

19. We note your disclosure in the first sentence of the second to
last paragraph concerning oral notice.  Please advise us as to how
oral notice is reasonably calculated to reach registered holders
of
the outstanding notes or otherwise satisfies the requirements of
Rule
14e-1(d).

Procedures for Tendering, page 14

20. We note that you state that "[u]nless waived, any defects or
irregularities in connection with tenders of outstanding notes
must
be cured within such time as we will determine."  All offer
conditions, except those related to the receipt of government
regulatory approvals necessary to consummate the offer, must be
satisfied or waived at or before the expiration of the offer.
Revise
your disclosure on page 16 accordingly.


21. We note the disclosure indicating that you will return any old
notes not accepted for exchange "as soon as practicable" after the
expiration date of the exchange offer.  Rule 14e-1(c) requires
that
you exchange the notes or return the old notes "promptly" upon
expiration or termination of the offer, as applicable.  Please
revise
here and throughout the document, as necessary.

Ranking, page 22

22. State the amount of subordinated debt outstanding for American
Standard Inc. as of the most recent date practicable.  In
addition,
state the amount of unsecured unsubordinated obligations of each
guarantor, as well as the amount of any debt held by the
guarantors
that ranks senior to the guarantees.  Also include this revised
disclosure in your summary on page 6.

Material Federal Income Tax Considerations, page 31

23. Please delete the statement on page 35 that the tax discussion
is
for "general information only."  Please also revise your statement
on
page 31 that you "intend this discussion to be a general
description
of the U.S. federal income tax considerations material to the
exchange...."

Independent Registered Public Accounting Firm, page 149

24. Since the auditor has consented to the use of its name
certifying
the financial statements included in the registration statement,
please revise to list them as "Experts."

Legal Matters, page 36

25. Please give the address for McDermott Will & Emery LLP.  See
paragraph 23 of Schedule A to the 1933 Act.

26. Please also state that McDermott Will & Emery LLP has passed
on
the enforceability of obligations under the exchange notes and the
guarantees.

Item 21.  Exhibits and Financial Statement Schedules

27. Please file the registration rights agreement as an exhibit to
the registration statement.

28. A legality opinion is required to be filed with this
registration
statement.  Please file the opinion with the next amendment.


Exhibit 23.1

29. Please make arrangements with Ernst & Young LLP to have them
update their consent to include the complete Form S-4 filing
number.
Please also ensure that the updated consent is signed and covers
the
reference to them on page 36.

Exhibit 99.1 - Letter of Transmittal

30. We note the statement on page 6 that you will return any
outstanding notes not accepted for exchange "as promptly as
practicable" after expiration or termination of the Exchange
Offer.
Rule 14e-1(c) requires that you exchange the notes or return the
old
notes "promptly" upon expiration or termination of the offer, as
applicable.  Please revise this statement and a similar statement
on
page 11.

31. To the extent necessary, please make any changes requested by
the
above comments relating to the prospectus in the letter of
transmittal as well.

Form 10-K for fiscal year ended December 31, 2004 and Form 10-Q
for
fiscal quarter ended March 31, 2005

Comments applicable to your overall filing

32. Please address the comment above regarding your Selected
Consolidated Financial Data in your Form 10-K as well.

33. Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like.  These revisions should be
included in your future filings.

Item 1. Business, page 1
General, page 6
Raw Materials, page 6

34. Please expand your disclosure to discuss any material
contracts
you have entered into relating to energy and materials used in the
production of your products.

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 21
Results of Operations for 2004 Compared with 2003 and 2003
Compared
with 2002, page 22

35. Your discussion regarding your results of operations includes
segment income and total segment income, which outside the context
of
your SFAS 131 disclosure are non-GAAP financial measures.  Please
expand your disclosure to include the following:
* a discussion which details why the presentation of total segment
income provides useful information to investors regarding your
financial condition and results of operations,
* a reconciliation and discussion regarding segment income and
total
segment income to the most directly comparable financial measure
calculated and presented in accordance with GAAP, and
* disclosure stating total segment income may not be comparable to
those of other entities, as not all companies and analysts
calculate
this non-GAAP measure in the same manner.
Where applicable, please include the above in the other parts of
your
document where these non-GAAP financial measures are presented.
Refer to SEC Release No. 33-8176, Item 303 of Regulation S-K, and
Questions 19-21 of SEC FAQ dated June 13, 2003.

36. You have referenced in your segment discussion in Item 1
various
new products and product lines, including the expansion of
existing
product lines.  Please expand your disclosure to discuss the
impact
these new products, product lines and the expansion of existing
product lines have had and may have on your results of operations
and
liquidity.

37. You have disclosed various components, which have contributed
to
increases and decreases within your income statement line items,
including but not limited to, segment sales, segment income, and
corporate and other expense.  Some of the components you have
cited
include the following:
* higher volume and improved mix,
* productivity initiatives,
* new products sold,
* prior year job eliminations,
* incentive compensation, and
* post-retirement and medical costs.
Please expand your disclosure to include additional details that
explain the reasons for the changes and please quantify the
effects
each of these components had on the increases and decreases within
the income statement line items, including expenses that offset
one
another.  Please show us what your revised MD&A disclosure for
fiscal
2004 compared to 2003 will look like.

Liquidity and Capital Resources, page 31

38. Please expand your disclosure to discuss how the timing of
payments related to your increased exposure for asbestos-related
litigation will likely impact your liquidity.


39. Please expand your disclosure to include any legal
restrictions
you currently have regarding your ability or the ability your
subsidiaries have to pay dividends to affiliated companies and the
affect this may have on your future liquidity.  Refer to Item
303(a)
of Regulation S-K.

Financial Statements

Statement of Income, page 43

40. You disclosed on page 1 that your air conditioning systems and
services segment derives a portion of its revenue from service.
If
significant, please revise your statement of income to present
separately your sales and costs of sales related to service from
those related to products.  Refer to Rules 5-03(b)(1) and (2) of
Regulation S-X.

Notes to Financial Statements

41. You disclosed on page 48 that you have intangible assets.
Please
expand your disclosure to include the disclosures required by
paragraphs 44 and 45 of SFAS 142.

Note 2. Accounting Policies, page 47

42. Your disclosure on page 1 indicates that your air conditioning
systems and services segment utilizes independent agents and
distributors to distribute its products.  You also disclosed that
you
utilize distributors for your kitchen and bath and your vehicle
control systems segments.  You further disclosed on page 25 you
have
a marketing arrangement with Home Depot relating to your air
conditioning systems and services segment.  You also disclosed
sales
to Home Depot and Lowe`s were included in your kitchen and bath
segment.  If you pay slotting fees, engage in cooperative
advertising
programs, have buydown programs, or make other payments to
resellers,
please disclose your accounting policy for each of these types of
arrangements, including the statement of income line item that
each
type of arrangement is included in.  For each expense line item
that
includes these types of arrangements, please disclose the related
amounts included in that line item.  For each type of arrangement
treated as an expense rather than as a reduction of revenues,
please
tell us how this type of arrangement meets the requirements in
EITF
01-9.  Please also discuss in MD&A any significant estimates
resulting from these arrangements.

43. Please disclose the method you use to record and reissue
treasury
stock.  Refer to paragraphs 12(b) and 13 of APB 6.


Revenue Recognition, page 47

44. Please expand your disclosure related to your accounting
policy
for the percentage-of-completion method to include your policy
regarding change orders that have not yet been approved by the
customer, including how you treat the profit component of the
unapproved change orders.

Shipping and Handling Costs, page 47

45. Please disclose the types of expenses that you include in the
cost of sales line item and the types of expenses that you include
in
the selling, general and administrative expenses line item.  You
have
disclosed that shipping and handling costs incurred on sales of
products are included in cost of sales.  Please expand your
disclosure to include whether you include purchasing and receiving
costs, inspection costs, warehousing costs, internal transfer
costs,
and the other costs of your distribution network in your cost of
sales line item.  With the exception of warehousing costs, if you
currently exclude a portion of these costs from cost of sales,
please
disclose:
* in a footnote the line items that these excluded costs are
included
in and the amounts included in each line item for each period
presented, and
* in MD&A that your gross margins may not be comparable to those
of
other entities, since some entities include all of the costs
related
to their distribution network in cost of sales and others like you
exclude a portion of them from gross margin, including them
instead
in another line item, such as selling and administrative expenses.

Goodwill and Intangible Assets, page 48

46. Your disclosure indicates that you have intangible assets
deemed
to have indefinite lives, which are not amortized.  Please expand
your disclosure to identify which intangible assets you have
determined to have indefinite lives.  In addition, please tell us
the
facts and circumstances you considered in reaching your conclusion
that these intangible assets have indefinite lives.  Refer to
paragraph 11 of SFAS 142.

Earnings per share, page 48

47. For each of the periods presented, please expand your
disclosure
to include the amount of securities that were not included in the
calculation of diluted EPS because they would have had an
antidilutive effect.  Refer to paragraph 40(c) of SFAS 128.



Note 14. Warranties, Guarantees, Commitments and Contingencies,
page
66

48. Please address the comments below related to note 14 in your
Item
3 disclosure as well.

49. Your disclosure regarding the investigations by the French
Competition Council indicates that the outcome these
investigations
could be material to your operating results.  Please expand your
disclosure to include your conclusion and the related assumptions
used to determine your conclusion based on the guidance in
paragraphs
3 and 8-10 of SFAS 5 relating to this matter.

50. You disclosed that you historically recorded liabilities for
only
claims that had been filed.  You further disclose that due to the
stabilization in the rates at which new claims are filed and your
added experience you can now reasonably estimate the liability.
Please disclose the facts and circumstances that changed your
assessment regarding your ability to reasonably estimate the
liability.

51. Your disclosure indicates that HR&A calculated a total
estimated
liability associated with the asbestos claims through 2055.
Please
provide us with your analysis related to your asbestos liability
activity for each of the balance sheet dates for the next five
years.
In addition, please tell us how you determined that the claims you
have accrued through 2055 meet the probable and reasonably
estimable
criteria in paragraph 8 of SFAS 5.

52. You disclosed that you recorded a $309 million receivable for
probable asbestos-related insurance recoveries.  You later
disclosed
that you are in litigation with certain carriers whose policies
you
believe provide coverage for pending claims and that these
carriers
are challenging your right to recovery.  Please expand your
disclosure to clarify whether the recovery amounts in dispute with
these carriers are included in the $309 million receivable you
recorded.  If these disputed amounts are included in the $309
million
receivable recorded, please tell us the facts and circumstances
and
the accounting guidance you considered in reaching your
conclusion.
In addition, please expand your disclosure to include the total
amount of recoveries you have received from your insurance
carriers
and the amount you have settled with insurance carriers, but have
not
received relating to asbestos-related claims.  You also disclosed
settlements total $51 million as of December 31, 2004.  Please
clarify if this is net of insurance recoveries.

53. You disclosed the average payment per claim for settlements
made
was $2,003.  Please expand your disclosure to include the average
settlement amount for cases closed in each period presented.



Note 15. Segments, page 71

54. If significant, please expand your disclosure to separately
disclose sales derived from services from those derived from
product
sales.  Refer to paragraph 37 of SFAS 131.

55. Please expand your disclosure to discuss the types of expenses
you include in corporate and other expenses line item for each
period
presented.

Item 9A.  Controls and Procedures, page 84

56. In future filings, please revise your disclosure regarding
management`s conclusion regarding the effectiveness of your
disclosure controls to clarify, if true, that your officers
concluded
that your disclosure controls and procedures are also effective to
ensure that information required to be disclosed in reports that
you
file or submit under the Exchange Act is accumulated and
communicated
to your management, including your chief executive officer and
chief
financial officer, to allow timely decisions regarding required
disclosure.

FORM 10-Q FOR THE PERIOD ENDED MARCH 31, 2005

Comments applicable to your overall filing

57. Please address the comments above in your interim Forms 10-Q
as
well.

Closing Comments

      As appropriate, please amend your registration statement 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 supplemental 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 filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 disclosures they
have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, 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 this action 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 registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  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 direct accounting comments to Meagan Caldwell, Staff
Accountant, at (202) 551-3754 or, in her absence, to Rufus Decker,
Branch Chief, at (202) 551-3769.  Direct questions on disclosure
issues to Tamara Brightwell, Staff Attorney, at (202) 551-3751 or,
in
her absence, to Lesli Sheppard, Senior Staff Attorney, at (202)
551-
3708, or the undersigned at (202) 551-3760.


Sincerely,



Pamela A. Long
Assistant Director

cc: 	Neal J. White, Esq.
	David A. Cifrino, Esq.
	McDermott Will & Emery LLP
	227 West Monroe Street
	Chicago, Illinois 60606-5096

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Mary Beth Gustafsson
American Standard Inc.
June 10, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE