Subject: File No. 4-500
From: Michael D. Lockhart, Chairman and Chief Executive Officer
Affiliation: Armstrong Holdings, Inc.

June 9, 2005

From: Michael D. Lockhart, Chairman and Chief Executive Officer
Armstrong Holdings, Inc.
2500 Columbia Avenue
Lancaster, PA 17603

Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Re: SEC File Number 4-500; Request for Rulemaking Regarding Member Records of “Short” Positions and Reporting and Public Dissemination of Aggregate Positions by Security

Dear Secretary Katz:

Please be advised that Armstrong Holdings, Inc. supports the proposal to require broker dealers to maintain a record of their “short” positions in all publicly-traded equity securities and report this information for public dissemination. This uniform rule across all public markets will help prevent fraudulent acts, expose market manipulation and better protect investors.

Armstrong Holdings, Inc.’s common stock has been trading on the Pink Sheets for several years. We are an international company with over $3 billion in annual sales and thousands of employees worldwide. Historically, a significant number of shareholders have been Armstrong retirees and their family members. In our view, protection of investors is the paramount concern in any public securities market. The current lack of transparency for short sales in over-the-counter markets is a disservice to public investors. The same basic standards for open trading should apply to all public markets.

We urge the Commission to act on this matter without delay.


Michael D. Lockhart, Chairman and Chief Executive Officer

Barbara Z. Sweeney
Senior Vice-President and Secretary
1735 K Street, NW
Washington, DC 20006-1500
Walter T. Gangl, Esq., Assistant Secretary
Armstrong Holdings, Inc.