Mail Stop 6010
      October 17, 2005

VIA U.S. MAIL AND FACSIMILE (847) 229-2235

Laurence P. Birch
Chief Financial Officer
Aksys, Ltd.
Two Marriott Drive
Lincolnshire, Illinois  60069


      Re:	Aksys, Ltd.
		Form 10-K for the year ended December 31, 2004
      Filed March 16, 2005
      Form 10-Q for the quarterly period ended June 30, 2005
		File No. 000-28290

Dear Mr. Birch:


      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise future filings 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 year ended December 31, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Results of Operations

Year Ended December 31, 2004 Compared to Year Ended December 31,
2003

Revenue, page 31

1. We see your discussion of the 60% increase in revenue from the
year ended December 31, 2003 and note that you sold 27 systems and
generated rental revenue on 71 units in fiscal year 2004 compared
to
the sale of 28 systems and rental revenue on 31 units in fiscal
year
2003.  Please tell us and revise future filings to disclose the
revenue generated from sales of products versus rental of units.
In
addition, please clarify how the changes in number of units sold
or
units under operating leases contributed to the changes in revenue
during the periods presented, for example through a discussion of
changes in average product price or rental rates.

Consolidated Financial Statements

Note 1.  Summary of Significant Accounting Policies, page 46

(f) Long-Lived Assets, page 47

2. We note that certain PHD machines used as demonstration models
or
internal training are transferred from inventory to equipment and
depreciated over their useful life.  We note that you also
transfer
machines from inventory to leased assets.  Tell us how you account
for these transfers in your consolidated statement of cash flows.
Additionally, clarify what line item you record the depreciation
of
the demonstration or training products.

Note 2.  Investments, page 51

3. In future filings, please disclose information about the
contractual maturities of all long-term securities, as required by
paragraph 20 of SFAS 115.


Form 10-Q for the quarterly period ended June 30, 2005

Consolidated Financial Statements

Note 12.  Significant Estimate for Product Warranty, page 11

4. We see that you recorded a significant charge in the six months
ended June 30, 2005 to establish a product warranty reserve.  In
future filings, please disclose your accounting policy and
methodology used in determining your liability for product
warranties.  Please also refer to the disclosure requirements of
paragraph 14 of FIN 45.

5. As a related matter, please tell us the facts and circumstances
that resulted in the establishment of a product warranty liability
in
2004.  That is, please discuss why a reserve was not deemed
necessary
in prior fiscal years.

Item 2.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Comparison of Results of Operations

Six Months Ended June 30, 2005 Compared to Six Months ended June
30,
2004

Revenue, page 15

6. Refer to your disclosure that explains the 50% decrease in
revenue
as a result of a decrease in units sold.  Please expand in future
filings to identify and describe factors responsible for the
decrease
in the number of units sold compared to the prior year.  In
general,
MD&A both should identify factors responsible for changes in
financial statement items and describe why those factors arose or
occurred.

Cost of Sales, page 16

7. We see that you recorded a $1.4 million charge during the six
months ended June 30, 2005 related to the impairment of leased
assets.  Please tell us and disclose in future filings the
specific
events or circumstances that resulted in your decision to replace
the
older models in December 2006.  Please also clarify whether the
impaired rental machines will be sold or otherwise disposed.
8. We note your use of the non-GAAP measure "cost of sales
excluding
impairment, warranty reserve and obsolescence reserve."  This
measure
does not appear to comply with the guidance provided in SEC Rule
34-
47226 - Conditions for Use of Non-GAAP Financial measures or the
Staff`s FAQ Regarding the use of Non-GAAP Financial Measures since
they appear to exclude recurring items.  Please revise future
filings, beginning with your next Form 10-Q, to remove this
measure.
Please refer to Questions 8 and 9 of the FAQ.

9. As a related matter, please refer to the disclosure
requirements
of Item 10(e)(1)(i) of Regulation S-K.  Under that guidance you
should disclose, with equal or greater prominence, the most
directly
comparable GAAP measure and you should provide reconciliation of
the
differences between those non-GAAP and GAAP measures. You should
also
provide substantive statements disclosing the reasons why you
believe
a non-GAAP measure provides useful information to investors. In
that
regard, you should expand the existing statements to provide more
specific rationale for your use and disclosure of the measures.
Please apply in all future filings.

      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 letter with your response 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.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 filing;

* staff comments or changes to disclosure in response to staff
comments 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.

	You may contact Kristin Lochhead at (202) 551-3664 or me at
(202) 551-3604 if you have questions.  In this regard, please do
not
hesitate to contact Brian Cascio, Accounting Branch Chief at (202)
551-3676 with any other questions.


      Sincerely,



      Kate Tillan
      Assistant Chief Accountant

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Mr. Birch
Aksys, Ltd.
October 17, 2005
Page 2