Mail Stop 03-05
      June 9, 2005


Thomas J. Snyder
President and Chief Executive Officer
Remy International, Inc.
2902 Enterprise Drive
Anderson, Indiana 46013

      RE:	Remy International, Inc.
    	Form 10-K for the fiscal year ended December 31, 2004
    	Form 10-Q for the quarter ended March 31, 2005
    	File No. 001-13683

Dear Mr. Snyder:

      We have reviewed the above referenced filings and have the
following comments.  We have limited our review to the financial
statements and related disclosures included within these
documents.
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 filings.

      Unless otherwise indicated, where expanded or revised
disclosure is requested, you may comply with these comments in
future
filings.  If you disagree, we will consider your explanation as to
why our comments are inapplicable or a revision is unnecessary.
In
some of our comments, we may ask you to provide us with additional
information so we may better understand your disclosure.  Please
be
as detailed as necessary in your explanations.  We look forward to
working with you in these respects and welcome any questions you
may
have about any aspects of our review.

Form 10-K for the fiscal year ended December 31, 2004

Note 7 - Accounts Receivable and Allowance for Doubtful Accounts,
page 48

1. The balance of the allowance for doubtful accounts decreased
year
over year from 4.3% of the December 31, 2003 accounts receivable
balance to 1.8% of the December 31, 2004 accounts receivable
balance.
In addition, the balance of your accounts receivable at March 31,
2005 has increased approximately $22 million since December 31,
2004.
Please provide a roll forward of the allowance for doubtful
accounts
from December 31, 2004 to March 31, 2005 and provide this
information
in future filings.  In addition, tell us what factors contributed
to
the decrease in the allowance for doubtful accounts from December
31,
2003 to December 31, 2004.

2. We note that you currently employ two programs to accelerate
the
collection of accounts receivable.  Please tell us how you are
accounting for the discounts on your receivables for each of these
programs and specifically note where these discounts are
classified
in your financial statements.

Form 10-Q for the period ended March 31, 2005

Note 3 - Acquisitions, page 7

3. We note the acquisition of Unit Parts Company ("UPC") on March
18,
2005.  Please tell us how you have evaluated the significance of
the
UPC acquisition under Regulation S-X, Article 03-05(b)(2).  In
this
regard, we note that it appears that UPC would be significant to
your
business as the total UPC assets ($157.5 million) are in excess of
20% of the December 31, 2004 total assets of the Company ($755.7
million).  If UPC is significant to your business under
significance
tests specified by the regulation, you should submit the required
audited financial statements for UPC and pro-forma financial
statements as required.  We note that if required, this
information
was due within 75 days of the acquisition as an amendment to your
Form 8-K (filed March 22, 2005) announcing the acquisition.  For
guidance, refer to Regulation S-X, Article 03-05 and Regulation S-
X,
Article 11.


* * * * *

	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.
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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments 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 our review of your filing or in
response to our comments on your filing.

      Please file your response to our comments via EDGAR within
fifteen business days from the date of this letter.  Please
understand that we may have additional comments after reviewing
your
response.  You may contact Cari Kerr at 202-551-3310 or the
undersigned at 202-551-3812 with any questions.


      Sincerely,



								Michael Fay
								Branch Chief


Via Fascimile: Rajesh K. Shah, Executive VP and CFO, 765-778-6424

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Thomas J. Snyder
Remy International, Inc.
June 9, 2005
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