UPLOAD: SEC-generated letter

Mail Stop 0510

May 27, 2005

Mr. Andy L. Nemeth
Chief Financial Officer, Patrick Industries, Inc.
1800 South 14th Street
P.O. Box 638
Elkhart, Indiana 46515

RE: Form 10-K for the fiscal year ended December 31, 2004
File No. 0-3922


Dear Mr. Nemeth:

We have reviewed your response and have the following
additional comments. If you disagree with a comment, 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.

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 on 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 December 31, 2004

General
1. Where a comment below requests additional disclosures or other
revisions, please show us in your response what the revisions will
look like. These revisions should be included in your future
filings, including your interim filings where appropriate.


Management`s Discussion and Analysis, page 14

Results of Consolidated Operations, page 17

Business Segments, page 19
2. We have reviewed your response to comment 2. To the extent
practicable, please revise your proposed MD&A disclosures to
quantify
the incremental impact of individual factors, such as volume and
pricing, identified as contributing to period-to-period
fluctuations.

Financial Statements, page F-2
3. We have reviewed your response to comment 5. If true, please
confirm that the proposed cash flows from operating activities in
your response are meant to be a positive $485 and a negative $345.

Note 1 - Nature of Business, Use of Estimates, Risks and
Uncertainties, and Significant Accounting Policies, page F-6
4. We have reviewed your response to comment 7. Please disclose
the
information in your response in your future filings. Further,
your
response appears to indicate that you do exclude some of the costs
related to your distribution network from costs of goods sold and
include such costs in the warehouse and delivery expenses line
item.
Accordingly, it appears your gross margins may not be comparable
to
those of other entities. Please provide us with additional
information to help us understand why you believe that further
disclosure is unnecessary.
5. Please also disclose where purchasing and receiving costs are
included on your statements of operations.

* * * *

Please respond to these comments within 10 business days
or
tell us when you will provide us with a response. Please provide
us
with a response letter that keys your responses to our comments
and
provides any requested information. Detailed 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 filings 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 filings;

* 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 Scott Watkinson at (202) 551-3741 or, in his
absence, me at (202) 551-3769 with any other questions.

Sincerely,



Rufus Decker
Accounting Branch Chief
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Mr. Andy L. Nemeth
May 27, 2005
Page 1 of 3




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

DIVISION OF
CORPORATION FINANCE