Mail Stop 0407

      							March 31, 2005

Via U.S. Mail and Fax
John B. Bartlett
Chief Financial Officer
UniFirst Corporation
68 Jonspin Road
Wilmington, MA  01887

	RE:	UniFirst Corporation
		Form 10-K for the fiscal year ended August 28, 2004
		Filed November 12, 2004
		File No. 001-08504

Dear Mr. Bartlett:
      We have reviewed your supplemental response letter dated
March
11, 2005 as well as the above referenced filings and have the
following comments.  As noted in our comment letter dated February
18, 2005, we have limited our review to your financial statements
and
related disclosures and will make no further review of your
documents.  As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.


Form 10-K for the year ending August 28, 2004

Item 8. Financial Statements and Supplementary Data

1. We note your response to prior comment 4. As you state in your
products and services description under Item 1, you provide full-
service rental programs in which you rent uniforms and provide
cleaning services, lease programs in which you rent uniforms (and
other products) but do not provide cleaning services, and purchase
programs in which you sell uniforms. Please tell us whether
revenues
from the lease programs are material and separately identifiable
in
your internal reports. If the lease program revenues are material
and
separately identifiable, as noted in our prior comment, please
revise
your Consolidated Statements of Income presentation in future
filings
to disclose separately rent revenues and associated costs in
accordance with Rule 5-03(b) of Regulation S-X. If the revision is
not appropriate, please explain why.

2. In order to clarify your response to comments 9 and 11, please
give us a better understanding of your operating segment and
component management structures.   Please provide us an
organizational chart that identifies the various levels of
management
and summarizes their responsibilities.  In this regard:
* Identify your chief operating decision maker and provide us
copies
of all reports that he reviews when allocating resources to and
assessing the performance of your operating segments;
* Identify your segment management, as defined in paragraph 14 of
SFAS 131;
* Indicate whether you have regional directors (or equivalents)
and,
if so, explain to us the function of the regional director and
identify who they report to in your organization.  Tell us what
financial information they provide to your chief operating
decision
maker, if any.   If they do provide financial information, please
give us examples of those reports and the reports of subordinates
upon which they rely in turn; and
* Tell us to whom your 140 US and Canadian Rental and Cleaning and
16
Specialty Garment Rental and Cleaning location supervisors report.
Provide us examples of all the financial information that you
regularly prepare on a location basis for upper management review.
Identify for us the management levels in your organization that
reviews this information.

3. We note your response to prior comment 9. In your response you
state that in order to determine the three reporting units as
defined
by SFAS 142 you aggregated 140 components, or locations, for the
US
and Canadian Rental and Cleaning reporting unit, and you
aggregated
16 components for the Specialty Garments Rental and Cleaning
reporting unit.  Please explain to us in more detail how your 140
US
and Canadian Rental and Cleaning and 16 Specialty Garment Rental
and
Cleaning locations are similar to each other economically in
accordance with paragraph 30 of SFAS 142.  Describe the extent to
which each of these locations conducts: design, manufacture,
purchase, rental, cleaning, delivery and sales operations; and in
this regard, give us a more detail description of how these
locations
meet each of the aggregation criteria of paragraph 17 of SFAS 131
and
the additional "similar economic characteristics" of EITF D-101.

4. We note in your response to prior comment 11 that the
description
of the typical Specialty Garment Rental and Cleaning operating
segment customers appears to differ from your typical customers as
described in Item 1 of your Form 10-K.   Further, it is not clear
from your response to comment 11 whether or not the Nuclear
Regulatory Commission environment imposes a more costly operating
restriction on your Specialty Garment Rental and Cleaning
operating
segment.  Please tell us the following:
* Describe the extent to which these two operating segments share
assets and equipment;
* Explain the extent to which you need to invest in different
equipment for each operating segment;
* Give us a better understanding of how your operating segment
customer bases differ;
* Describe the additional operational burdens imposed by the
Nuclear
Regulatory Commission on your Specialty Garment Rental and
Cleaning
operations and explain how these burdens affect the Specialty
Garment
Rental and Cleaning operating segment`s performance
characteristics;
* Quantify and compare the long-term financial performance
characteristics of US and Canadian Rental and Cleaning and
Specialty
Garment Rental and Cleaning operating segments, which you
considered
pursuant to paragraph 17 of SFAS 131; and
* Tell us the sales trends and average long-term average gross
margins for both operating segments.

5. Further, your response to comment 11 indicates that your First
Aid
operating segment does not meet any of the 10 percent threshold
criteria in paragraph 18 of Statement 131 and does not meet all of
the aggregation criteria in paragraph 17 with another segment that
does meet at least one of the 10 percent threshold criteria.
Consequently, it appears that your First Aid operating segment
cannot
be aggregated.  Please disclose this operating segment separately
in
an "all other" category as required by paragraph 21 of SFAS 131.

Form 10-Q for the quarters ended November 27, 2004

6. Please comply with all of the above comments in your future
filings as applicable.



*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides all
requested information.  Please file your response letter on EDGAR.
You may contact Joe Cascarano, Staff Accountant, at (202) 824-5357
or
Joe Kempf, Senior Staff Accountant, at (202) 942-1979 if you have
questions.

							Sincerely,



							Larry Spirgel
							Assistant Director
John B. Bartlett
UniFirst Corporation
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