Mail Stop 3561

				March 30, 2006

By Facsimile and U.S. Mail

Mr. Vincent Russo
Chief Accounting Officer
Phillips-Van Heusen Corporation
200 Madison Avenue
New York, New York 10016

		Re:	Phillips-Van Heusen Corporation
			Form 10-K for the year ended January 30, 2005
			Filed April 14, 2005
			File No. 1-07572

Dear Mr. Russo:

	We reviewed your responses to our prior comments on the above
referenced filings as set forth in your letter dated March 22,
2006.
Our review resulted in the following accounting comment.

Form 10-K for the Year Ended January 30, 2005

1. We note your response to comment four of our letter dated
February
9, 2006.  Paragraph 17 of SFAS 131 and EITF Issue no. 04-10
indicate
that operating segments must have similar economic characteristics
in
order to justify aggregation into one reportable segment.
Further,
aggregation of operating segments requires that all aggregation
criteria are met in the case of operating segments that exceed
certain quantitative thresholds.  It appears that the gross
margins
for the three years ended 2004 are materially different among your
operating segments.  Furthermore, it does not appear that your
wholesale and retail businesses represent similar distribution
channels.  It appears that footwear and clothing such as shirts
are
not similar products given the different materials used to produce
these products and the general nature of the product itself.
Please
revise your segment disclosures included in the notes to the
financial statements included in your Form 10-K for the year ended
January 29, 2006. Provide to us a draft of your proposed
disclosure
and the justification for aggregation of operating segments into
reportable segments.

	```````````````````````````````````````````````As
appropriate,
please respond to this comment 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 response to our comment and
provides
any requested supplemental information.  Please file your response
letter on EDGAR as a correspondence file.

`		If you have any questions regarding this comment, please
direct them to Robert Babula, Staff Accountant, at (202) 551-3339
or,
in his absence, to the undersigned at (202) 551-3841.  Any other
questions regarding disclosures issues may be directed to H.
Christopher Owings, Assistant Director at (202) 551-3725.





			Sincerely,



			Michael Moran, Esq.
			Branch Chief


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Mr. Vincent Russo
Phillips-Van Heusen Corporation
March 30, 2006
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