Mail Stop 7010

                  January 19, 2006


James A. Cooley
Chief Financial Officer
Alliance One International, Inc.
512 Bridge Street
Danville, Virginia 24541

      Re:	Alliance One International, Inc.
		Form 10-K for the Year Ended March 31, 2005
		Filed on June 14, 2005
		File number 0-06529

Dear Mr. Cooley:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filings to those issues we have
addressed in our comments. Where indicated, we think you should
revise your document 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 supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not 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 March 31, 2005

Note N - Segment Information, page 70

1. We note your determination that your Italian processing
facility
qualified for accounting as a discontinued operation.  In this
regard, please supplementally support your conclusion that you
have
just one reportable segment as defined by SFAS 131.   That is,
tell
us whether you have discrete financial information as contemplated
by
paragraph 10 of SFAS 131 on a facility by facility basis.  Please
provide us with your detailed SFAS 131 analysis.  This would
include
your analysis of whether your business is comprised of multiple
operating segments meeting the definition provided in SFAS 131,
and,
if so, how those operating segments meet the aggregation criteria
described in paragraph 17, including similar economic
characteristics
such as gross margin.  Submit to us all financial reports given,
during the fourth quarter of fiscal 2005 and your most recent
quarter, to your chief operating decision makers and board members
who are responsible for allocating resources and assessing
performance of the enterprise.  Tell us whether your conclusions
in
this regard changed as a result of your May 2005 merger.

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

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 Yong Choi, staff accountant at (202) 551-
3758
or Sandy Eisen, senior staff accountant at (202) 551-3864 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3684 with any other
questions.

Sincerely,


April Sifford
Branch Chief

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James A. Cooley
Alliance One International, Inc.
January 19, 2006
Page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE