Mail Stop 7010 March 17, 2006 via U.S. mail and facsimile to (203) 254-6019 Mr. Paul G. Driscoll Vice President and Chief Financial Officer Acme United Corporation 60 Round Hill Road Fairfield, CT 06824 RE: Acme United Corporation Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 18, 2005 File No. 001-07698 Dear Mr. Driscoll: We have completed our review of your Form 10-K and have no further comments at this time. If you have any further questions regarding our review of your filings, please direct them to Ryan Rohn, Staff Accountant, at (202) 551-3739 or, in his absence, to Al Pavot, Staff Accountant, at (202) 551-3738, or to the undersigned at (202) 551-3255. Sincerely, Nili Shah Accounting Branch Chief ?? ?? ?? ?? UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE