Mr. Paul G. Driscoll, CFO					February 13,
2006
Acme United Corporation
60 Round Hill Road
Fairfield, CT  06824

RE:	Acme United Corporation  File No. 001-07698
      December 31, 2004 Form 10-K filed March 18, 2005

Dear Mr. Driscoll:

		We have reviewed your responses to our December 22, 2005
letter and have the following comment. 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. 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.

	     Paragraph 10 of SFAS No. 131 defines an operating
segment
as a component of an enterprise with discrete financial
information
that is regularly reviewed by the chief operating decision maker.
Based on your responses, it appears that you have four operating
segments. Paragraph 17 of SFAS No. 131 precludes the aggregation
of
operating segments that do not have similar economic
characteristics.
In this regard, we note that the U.S. segment has significantly
higher gross margins and operating margins than the other three
segments in all periods presented. The Canadian segment has
significantly higher operating margins that the European segment
in
all periods presented. The European segment has generated net
losses
in all periods presented, whereas the other three segments have
generated income. Therefore, it does not appear that these
segments
have exhibited similar long-term financial performance or that
they
have similar economic characteristics. Given the quantitative
thresholds outlined in paragraph 18 of SFAS No. 131, it appears
there
are 3 reportable segments requiring the disclosures prescribed by
SFAS 131. Also it appears your Asian segment may not be aggregated
with any of the three reportable segments due to the material
differences in economic characteristics. Please provide the
complete
SFAS 131 disclosures in future filings.

      Please direct any questions to Ryan Rohn at (202) 551-3739
or,
to Al Pavot at (202) 551-3738, or to the undersigned at (202) 551-
3255.

							Sincerely,


							Nili Shah
							Accounting Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE