Mail Stop 6010

      November 25, 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
		File No. 000-28290

Dear Mr. Birch:

      We have reviewed your response letter dated October 31, 2005
and related filing and have the following comments.  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 Operation

Results of Operations

Revenue, page 31

1. We note your response to comment one and six in our letter
dated
October 17, 2005 and the revised response included in your Form
10-Q
for the nine months ended September 30, 2005.  It does not appear
as
though your disclosure describes the circumstances that occurred
during the period under discussion that resulted in material
changes
to your revenue from sales of machines.  For example, your revenue
from product sales decreased 60% from the nine months ended
September
30, 2004 to the nine months ended September 20, 2005, yet your
discussion does not explain why this decrease has occurred.
Please
revise in future filings.
2. In addition, in future filings please clarify whether the
number
of patients includes those who are being treated through sales and
rentals or only through rentals.  You should also clearly disclose
how patient growth impacts your rental and service and supplies
revenue.

Consolidated Financial Statements

Note 1.  Summary of Significant Accounting Policies, page 46

(f) Long-Lived Assets, page 47

3. Refer to your response to prior comment two in our letter dated
October 17, 2005.  You explain that you record transfers of
machines
from inventory to equipment and leased assets as an outflow of
operating cash flows for inventory until the machine is placed in
service as demonstration equipment or rental units, which is shown
as
an outflow of cash as an investing activity.  It appears as though
you should only show cash used for the purchase of the machines as
cash used at the time the cash is disbursed and then disclose the
non-cash event of transferring the machines to service as
demonstration equipment or rental units as a footnote disclosure.
Please tell us in detail why you believe that your current
presentation complies with SFAS 95.



      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.

	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.
November 25, 2005
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