CORRESP 6 filename6.htm

Robins, Kaplan, Miller & Ciresi L.L.P.
2800 LaSalle Plaza
800 LaSalle Avenue
Minneapolis, MN 55402-2015

ERIC O. MADSON
(612) 349-0822

April 15, 2005

Via EDGAR
Securities and Exchange Commission
450 - 5th Street N.W.
Judiciary Plaza
Washington, D.C. 20549

Re:

Appliance Recycling Centers of America, Inc.
Amendment No. 1 to Registration Statement on Form S-2
Commission File No. 333-123005

Ladies and Gentlemen:

        On behalf of Appliance Recycling Centers of America, Inc. (the "Company"), we are transmitting for filing via EDGAR an Amendment No. 1 to the Company's Registration Statement on Form S-2 under the Securities Act of 1933, as amended, which was filed on February 25, 2005.

        We have received the Commission's comment letter dated March 2, 2005 with respect to the above-referenced filing. As requested, we are providing the following response. To facilitate your review, we have set forth below the full text of your comment before our response.

Selling Security Holders, page 35

1.

For each selling shareholder, please identify the beneficial owner that has the ultimate voting or investment control over the shares listed in your selling shareholder table on page 35 of your document. See Interpretation 60 under Section I. Regulation S-K in the Division of Corporation Finance's Manual of Publicly Available Telephone Interpretations (July 1997).

The Company has revised the table of selling shareholders to identify the beneficial owner that has the ultimate voting or investment control over the shares listed.

* * * * *

        Amendment No. 1 also includes the Company's financial statements for the fiscal year ended January 1, 2005 and related disclosures under Management's Discussion and Analysis.

        Please be advised that the Company intends to request that the Registration Statement be declared effective on Thursday, April 21, 2005. Its acceleration request will be submitted to you no later than Tuesday, April 19, 2005.

        If you have any questions regarding this filing, please contact me at (612) 349-0822.

Sincerely,

ROBINS, KAPLAN, MILLER & CIRESI L.L.P.

/s/ Eric O. Madson Eric O. Madson

DPP/mrs

Enclosures

cc (w/o enclosures): Edward R. (Jack) Cameron, Appliance Recycling Centers of America, Inc.