Mail Stop 6010
      April 24, 2006

Mr. Gordon A. Ulsh
President and Chief Executive Officer
Exide Technologies
13000 Deerfield Parkway, Building 200
Alpharetta, Georgia 30004

		RE: 	Exide Technologies
      Form 10-K for the fiscal year ended March 31, 2005
      Filed June 29, 2005
			File No.  1-11263

Dear Mr. Ulsh:

      We have reviewed your letter filed on March 31, 2006 and
have
the following comments.  Where indicated, we think you should
revise
your future documents 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 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.


Form 10-K for the fiscal year ended March 31, 2005

Note 3. Summary of Significant Accounting Policies, page F-14
1. Please refer to prior comment 4.  On pages F-16 and F-45 you
state
that the accrual for warranty and returns is estimated "based upon
historical trends and claims experience, and include assessment of
the anticipated lag between the date of sale and claim/return
date."
On page F-45, you state that you provide "customers with various
warranty and return privileges in each of [your] segments."  In
the
table on page F-46 you show a rollforward of the warranty
liability
account.  Please respond to the following comments:

* Please reconcile your response with the disclosures noted above.
Your response states that you primarily provide a sales discount
to
your customers in lieu of providing a warranty.  We note that the
table reflects warranty provisions of $37,445,000 in the successor
period.
* For those customers where you provide a warranty, your
accounting
and disclosures for the warranty, including the classification of
the
related costs, should be reflected in accordance with SFAS 5 and
FIN
45.  The accounting for sales returns should comply with SFAS 48.
You should separately present rollforwards of each reserve.  The
classification should be based upon the terms of the underlying
transactions and whether or not you are replacing damaged goods
for a
customer or accepting a return of a prior sale.
* Please provide us with a separate discussion and quantification
of
each of your various warranty and return programs and how you
account
for each under U.S. GAAP.


Note 11. Accounting for Goodwill and Intangibles, page F-28

2. Please refer to prior comment 10.  Please tell us and disclose
in
future filings how you applied the two-step process of SFAS 142 in
determining the implied fair value of your goodwill for each
reporting unit.  Your response only refers to the fair value of
the
company as a whole based upon your market capitalization.  Please
reconcile your disclosure on page F-28 stating that you utilized
an
updated five-year business plan as the basis for your discounted
cash
flows and an estimate of fair values.  Please also discuss your
consideration of paragraphs 23 - 25 and footnote 16 of SFAS 142.
We
note that you have four business segments.  Please tell us about
your
reporting units under SFAS 142 and how you tested goodwill for
impairment at the reporting unit level in accordance with
paragraph
18 of SFAS 142.  Please also tell us and disclose in future
filings
the changes in the carrying amount of goodwill during the period
for
each reportable segment and any significant changes in the
allocation
of goodwill by reportable segment.  See paragraph 45(c) of SFAS
142.

3. Please refer to prior comment 11.  Your response does not
appear
to address our prior comment with respect to the intangible asset
for
your customer relationships of $101,938 which represents
approximately half of your intangible assets.  Please tell us how
you
initially valued this asset at the date of fresh start reporting
and
subsequent tests for recoverability supporting your conclusion
that
there was no impairment of this asset as of March 31, 2005.
Please
address your consideration of paragraph 29 of SFAS 142 and
paragraphs
A20 and A21 of SFAS 141.


Note 14 - Debt, page F-29

4. Please refer to prior comment 13.  We note from your
disclosures
that the conversion rate on your Floating Rate Convertible Senior
Subordinated Notes is 57.5705 shares per $1 principal amount,
while
your disclosure on Form S-3 filed September 14, 2005 indicates
that
the conversion rate on the notes is 57.5705  per $1,000 principal
amount of notes.  Please reconcile.  Please also tell us and
disclose
in future filings the terms related to the redemption of the notes
in
the event of a change in control.  Tell us about your evaluation
of
whether or not this term is an embedded derivative under SFAS 133
that should be separately stated at fair value.

	As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover that keys your responses to our comments
and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

      You may contact Eric Atallah, Staff Accountant at (202) 551-
3663 or me at (202) 551-3604 regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Angela Crane, Branch Chief, at (202) 551-3554 with any
other
questions.

								Sincerely,



								Kate Tillan
								Assistant Chief Accountant
Gordon A. Ulsh
Exide Technologies
April 24, 2006
Page 3