November 28, 2007

Melissa N. Rocha, CPA

Division of Corporation Finance

Securities and Exchange Commission

Mail Stop 7010

100 F Street, NE

Washington, DC 20549

Re:	Church & Dwight Co., Inc
	Form 10-K for Fiscal Year Ended December 31, 2006
	File No. 001-10585

Dear Ms. Rocha:

Thank you for your prompt response to our letter dated November 2, 2007. As requested, we have provided the following related to your specific questions.

1.   Elaborate on your description of competitive activity as used in the intangible asset disclosure.

In future filings, we will change our description from “competitive activity” to specifically state “lost distribution at key customer accounts”.  Please see the revised disclosure.

The Company recorded trademark impairment charges within selling, general and administrative expenses as follows:

Segment:	2007		2006		2005
Consumer Domestic	$	XX	$	11.0	$	3.2
Consumer International	$	XX	$	3.3	$	3.1
Total	$	XX	$	14.3	$	6.3

The impairment charges were recorded as a result of lost distribution at key customer accounts causing lower forecasted sales and profitability.  The amount of the impairment charge was determined by comparing the estimated fair value of the asset to its carrying amount.  Fair value was estimated based on a “relief from royalty” discounted cash flow method.  Under this method, the owner of an intangible asset must determine the arm's length royalty that likely would have been charged if the owner had to license that asset from a third party. The Company determined the remaining carrying value of all tradenames was recoverable based upon the forecasted cash flows and profitability of the brands.

During the fourth quarter of 2006, the Company determined that certain tradenames should be re-characterized from indefinite lived to finite lived assets. This conclusion was based upon recurring impairment charges, continued competition in the marketplace, and the determination of a key customer to discontinue a product sold under one of these tradenames.   The carrying value of these tradenames as of December 31, 2006 was approximately $20.0 million, and is being amortized over lives ranging from 3 to 15 years beginning on January 1, 2007.  These lives were determined based upon the estimated future cash flows of these brands.

2.   In respect to the guarantor financial information provided in the Company’s September 28, 2007 Form 10-Q, you asked that:

a.   We review the requirements of Section 3-10 (I) (3), and provide draft condensed consolidated financial statements which include, in the parent column, the parent's equity income in the guarantor and non-guarantor subsidiaries. 

The Company has reviewed the requirement of Rule 3-10 (I) (3) and acknowledges the need to revise our presentation to include our 100% owned subsidiaries under the equity method of accounting.   Please refer to the revised presentation.

b.   We explain the sales and cost of sales eliminations

In response to your question, we have modified our presentation to appropriately reflect the elimination of intercompany sales and profit in inventory.  We have also changed our allocation of income tax expense.  Please refer to the revised presentation.

It is still the Company’s intent to incorporate these changes on a prospective basis in its 2007 Form 10-K as it will be available in the near future.

Thank you for your consideration. If you have any further questions or comments, please address them to Steven J. Katz, Vice President, Controller at (609)-497-7120.

Sincerely,

CHURCH & DWIGHT CO., INC

By: /s/ Matthew T. Farrell

Matthew T. Farrell

Executive Vice President Finance and Chief Financial Officer

Supplemental Financial Information of Guarantor and Non-Guarantor Operations

The Company’s 6% senior subordinated notes are fully and unconditionally guaranteed, by certain 100% owned domestic subsidiaries of the Company on a joint and several basis. The following information is presented in response to Rule 3-10 of Regulation S-X, promulgated by the Securities and Exchange Commission.  The Guarantor subsidiaries’ net sales are principally to, and other operating activities are principally with, the Company, which is referred to in the table below as “Parent”.

Supplemental information for the condensed consolidated balance sheets at September 28, 2007 and December 31, 2006, and the condensed consolidated income statements for the three and nine months ended September 28, 2007 and September 29, 2006, and condensed consolidated statements of cash flows for the nine months ended September 28, 2007 and September 29, 2006 are summarized as follows (amounts in thousands):

Statements of Income	For the Three Months Ended September 28, 2007
				Guarantor		Non-Guarantor						Total
	Parent			Subsidiaries		Subsidiaries			Eliminations			Consolidated
Net Sales	$	471,833		$	34,820	$	120,289		$	(46,504	)	$	580,438
Cost of sales		311,942			14,760		69,242			(44,913	)		351,031
Gross Profit		159,891			20,060		51,047			(1,591	)		229,407
Marketing expenses		52,544			-		17,156			-			69,700
Selling, general and administrative expenses		45,789			10,868		14,435			-			71,092
Income from Operations		61,558			9,192		19,456			(1,591	)		88,615
Equity in earnings of affiliates		28,618			-		1,311			(28,132	)		1,797
Investment earnings		1,053			215		696			-			1,964
Intercompany dividends/interest		(11,762	)		10,319		1,443			-			-
Other income (expense), net		1,020			-		312			-			1,332
Interest expense		(12,494	)		-		(1,995	)		-			(14,489	)
Income before minority interest and taxes		67,993			19,726		21,223			(29,723	)		79,219
Minority interest		-			-		(9	)		-			(9	)
Income before income taxes		67,993			19,726		21,232			(29,723	)		79,228
Income taxes		15,259			7,161		5,665			(573	)		27,512
Net Income	$	52,734		$	12,565	$	15,567		$	(29,150	)	$	51,716

	For the Three Months Ended September 29, 2006
				Guarantor			Non-Guarantor						Total
	Parent			Subsidiaries			Subsidiaries			Eliminations			Consolidated
Net Sales	$	425,438		$	30,873		$	102,839		$	(40,572	)	$	518,578
Cost of sales		282,765			13,058			60,146			(40,351	)		315,618
Gross Profit		142,673			17,815			42,693			(221	)		202,960
Marketing expenses		47,605			-			15,015			-			62,620
Selling, general and administrative expenses		53,929			1,906			15,616			-			71,451
Income from Operations		41,139			15,909			12,062			(221	)		68,889
Equity in earnings of affiliates		24,155			-			1,344			(23,622	)		1,877
Investment earnings		678			146			308			-			1,132
Intercompany dividends/interest		(10,611	)		9,593			1,018			-			-
Other income (expense), net		(360	)		(2	)		(328	)		-			(690	)
Interest expense		(12,764	)		-			(1,841	)		-			(14,605	)
Income before minority interest and taxes		42,237			25,646			12,563			(23,843	)		56,603
Minority interest		-			-			(4	)		-			(4	)
Income before income taxes		42,237			25,646			12,567			(23,843	)		56,607
Income taxes		3,432			9,489			5,102			(80	)		17,943
Net Income	$	38,805		$	16,157		$	7,465		$	(23,763	)	$	38,664

	For the Nine Months Ended September 28, 2007
				Guarantor		Non-Guarantor						Total
	Parent			Subsidiaries		Subsidiaries			Eliminations			Consolidated
Net Sales	$	1,344,519		$	100,371	$	330,765		$	(134,410	)	$	1,641,245
Cost of sales		894,780			42,375		190,115			(132,001	)		995,269
Gross Profit		449,739			57,996		140,650			(2,409	)		645,976
Marketing expenses		137,566			-		44,088			-			181,654
Selling, general and administrative expenses		151,656			18,103		47,255			-			217,014
Income from Operations		160,517			39,893		49,307			(2,409	)		247,308
Equity in earnings of affiliates		82,011			-		4,227			(80,421	)		5,817
Investment earnings		2,712			658		1,747			-			5,117
Intercompany dividends/interest		(33,896	)		29,086		4,810			-			-
Other income (expense), net		1,609			-		(168	)		-			1,441
Interest expense		(38,396	)		-		(5,510	)		-			(43,906	)
Income before minority interest and taxes		174,557			69,637		54,413			(82,830	)		215,777
Minority interest		-			-		(21	)		-			(21	)
Income before income taxes		174,557			69,637		54,434			(82,830	)		215,798
Income taxes		35,667			25,278		18,372			(867	)		78,450
Net Income	$	138,890		$	44,359	$	36,062		$	(81,963	)	$	137,348

	For the Nine Months Ended September 29, 2006
				Guarantor			Non-Guarantor						Total
	Parent			Subsidiaries			Subsidiaries			Eliminations			Consolidated
Net Sales	$	1,164,349		$	94,984		$	283,136		$	(122,916	)	$	1,419,553
Cost of sales		775,267			40,403			167,692			(120,554	)		862,808
Gross Profit		389,082			54,581			115,444			(2,362	)		556,745
Marketing expenses		111,545			-			38,629			-			150,174
Selling, general and administrative expenses		145,036			6,260			47,410			-			198,706
Income from Operations		132,501			48,321			29,405			(2,362	)		207,865
Equity in earnings of affiliates		70,681			-			3,377			(68,781	)		5,277
Investment earnings		1,999			508			1,122			-			3,629
Intercompany dividends/interest		(30,153	)		27,379			2,774			-			-
Other income (expense), net		2,819			(2	)		(988	)		-			1,829
Interest expense		(31,950	)		-			(5,479	)		-			(37,429	)
Income before minority interest and taxes		145,897			76,206			30,211			(71,143	)		181,171
Minority interest		-			-			(1	)		-			(1	)
Income before income taxes		145,897			76,206			30,212			(71,143	)		181,172
Income taxes		29,368			28,196			9,441			(850	)		66,155
Net Income	$	116,529		$	48,010		$	20,771		$	(70,293	)	$	115,017

	September 28, 2007
				Guarantor			Non-Guarantor						Total
	Parent			Subsidiaries			Subsidiaries			Eliminations			Consolidated
Assets
Current Assets
Cash and cash equivalents	$	92,369		$	20,822		$	65,295		$	-		$	178,486
Accounts receivable, less allowances		308			1,782			269,712			-			271,802
Inventories		150,141			6,393			74,016			(10,400	)		220,150
Deferred income taxes		2,696			-			2,657			-			5,353
Note receivable – current		1,263			-			-			-			1,263
Prepaid expenses		6,172			-			4,558			-			10,730
Total Current Assets		252,949			28,997			416,238			(10,400	)		687,784
Property, Plant and Equipment (Net)		246,019			42,923			57,908			-			346,850
Note Receivable		3,666			-			16			-			3,682
Long-term Supply Contracts		2,716			-			-			-			2,716
Tradenames and Other Intangibles		415,880			177,030			77,908			-			670,818
Goodwill		675,605			-			12,932			-			688,537
Investments in Subsidiaries and Affiliates		572,782			-			(30,645	)		(532,152	)		9,985
Other Assets		90,917			338			6,063			(27,134	)		70,184
Total Assets	$	2,260,534		$	249,288		$	540,420		$	(569,686	)	$	2,480,556
Liabilities and Stockholders' Equity
Current Liabilities
Short-term borrowings	$	-		$	-		$	117,009		$	-		$	117,009
Accounts payable and accrued expenses		207,889			2,645			88,185			-			298,719
Current portion of long-term debt		33,665			-			-			-			33,665
Due to/from Subsidiaries		50,817			(89,391	)		64,063			(25,489	)		-
Income taxes payable		7,521			-			9,043			(3,744	)		12,820
Total Current Liabilities		299,892			(86,746	)		278,300			(29,233	)		462,213
Long-term Debt		715,830			-			-			-			715,830
Deferred Income Taxes		138,272			-			11,684			-			149,956
Deferred and Other Long Term Liabilities		71,218			61			1,934			-			73,213
Pension, Postretirement and Postemployment Benefits		33,425			-			16,528			-			49,953
Minority Interest		4			-			162			-			166
Commitments and Contingencies
Total Liabilities		1,258,641			(86,685	)		308,608			(29,233	)		1,451,331
Stockholders' Equity
Common Stock-$1.00 par value		69,985			225,703			64,687			(290,384	)		69,991
Additional paid-in capital		107,802			4,940			34,723			(34,934	)		112,531
Retained earnings		874,831			105,330			97,502			(212,190	)		865,473
Accumulated other comprehensive income (loss)		(5,939	)		-			34,900			(2,945	)		26,016
		1,046,679			335,973			231,812			(540,453	)		1,074,011
Common stock in treasury, at cost:		(44,786	)		-			-			-			(44,786	)
Total Stockholders’ Equity		1,001,893			335,973			231,812			(540,453	)		1,029,225
Total Liabilities and Stockholders’ Equity	$	2,260,534		$	249,288		$	540,420		$	(569,686	)	$	2,480,556

	December 31, 2006
				Guarantor			Non-Guarantor						Total
	Parent			Subsidiaries			Subsidiaries			Eliminations			Consolidated
Assets
Current Assets
Cash and cash equivalents	$	22,111		$	20,302		$	68,063		$	-		$	110,476
Accounts receivable, less allowances		1,511			1,357			228,535			-			231,403
Inventories		140,023			6,221			56,647			(7,991	)		194,900
Deferred income taxes		7,242			-			2,168			-			9,410
Prepaid expenses		6,325			-			3,556			-			9,881
Total Current Assets		177,212			27,880			358,969			(7,991	)		556,070
Property, Plant and Equipment (Net)		242,296			43,482			54,706			-			340,484
Note Receivable		4,928			-			298			-			5,226
Long-term Supply Contracts		3,307			-			-			-			3,307
Tradenames and Other Intangibles		427,538			177,068			74,681			-			679,287
Goodwill		673,368			-			12,933			-			686,301
Investments in Subsidiaries and Affiliates		516,637			-			(35,121	)		(471,122	)		10,394
Other Assets		68,455			411			13,576			(29,357	)		53,085
Total Assets	$	2,113,741		$	248,841		$	480,042		$	(508,470	)	$	2,334,154
Liabilities and Stockholders' Equity
Current Liabilities
Short-term borrowings	$	1,979		$	-		$	100,288		$	-		$	102,267
Accounts payable and accrued expenses		209,927			2,589			78,029			1			290,546
Current portion of long-term debt		38,144			-			-			-			38,144
Due to/from Subsidiaries		15,773			(69,242	)		81,391			(27,922	)		-
Income taxes payable		8,769			3,845			3,710			(2,877	)		13,447
Total Current Liabilities		274,592			(62,808	)		263,418			(30,798	)		444,404
Long-term Debt		792,925			-			-			-			792,925
Deferred Income Taxes		117,581			-			16,688			-			134,269
Deferred and Other Long Term Liabilities		45,639			36			1,088			-			46,763
Pension, Postretirement and Postemployment Benefits		34,154			-			17,485			-			51,639
Minority Interest		4			-			313			-			317
Commitments and Contingencies
Total Liabilities		1,264,895			(62,772	)		298,992			(30,798	)		1,470,317
Stockholders' Equity
Common Stock-$1.00 par value		69,985			225,703			60,685			(286,382	)		69,991
Additional paid-in capital		85,459			4,940			34,728			(34,728	)		90,399
Retained earnings		747,946			80,970			64,835			(153,621	)		740,130
Accumulated other comprehensive income (loss)		(5,708	)		-			20,802			(2,941	)		12,153
		897,682			311,613			181,050			(477,672	)		912,673
Common stock in treasury, at cost:		(48,836	)		-			-			-			(48,836	)
Total Stockholders’ Equity		848,846			311,613			181,050			(477,672	)		863,837
Total Liabilities and Stockholders’ Equity	$	2,113,741		$	248,841		$	480,042		$	(508,470	)	$	2,334,154

Statements of Cash Flow	For the Nine Months Ended September 28, 2007
				Guarantor			Non-Guarantor						Total
	Parent			Subsidiaries			Subsidiaries			Eliminations			Consolidated
Cash Flow From Operating Activities
Net Income	$	138,890		$	44,359		$	36,062		$	(81,963	)	$	137,348
Adjustments to reconcile net income to net cash provided  by operating activities:
Depreciation and amortization		35,061			2,686			5,350			-			43,097
Equity in earnings of affiliates		(82,011	)		-			(4,227	)		80,421			(5,817	)
Distributions from affiliates		24,966			-			3,898			(23,493	)		5,371
Deferred income taxes		19,594			-			1,690			-			21,284
Asset impairment charges and other asset write-offs		1,409			518			(3,129	)		-			(1,202	)
Non cash compensation expense		8,991			-			-			-			8,991
Unrealized foreign exchange gain		(1,101	)		-			(1,207	)		-			(2,308	)
Other		198			-			-			-			198
Change in assets and liabilities:
Accounts receivable		1,202			(425	)		(35,350	)		-			(34,573	)
Inventories		(11,220	)		(172	)		(12,777	)		2,409			(21,760	)
Prepaid expenses		154			-			(679	)		-			(525	)
Accounts payable and accrued expenses		(2,338	)		56			5,093			-			2,811
Income taxes payable		7,225			-			5,262			(867	)		11,620
Excess tax benefit on stock options exercised		(5,509	)		-			-			-			(5,509	)
Intercompany activity		37,919			(23,655	)		(14,264	)		-			-
Other liabilities		2,599			24			(2,390	)		-			233
Net Cash Provided By Operating Activities		176,029			23,391			(16,668	)		(23,493	)		159,259
Cash Flow From Investing Activities
Additions to property, plant and equipment		(26,751	)		(2,945	)		(6,539	)		-			(36,235	)
Proceeds from sale of assets		-			-			7,213			-			7,213
Intercompany Investing		4,165			-			-			(4,165	)		-
Acquisitions (net of cash acquired)		(211	)		-			-			-			(211	)
Return of capital from equity affiliates		900			-			900			(900	)		900
Contingent acquisition payments		(1,002	)		-			-			-			(1,002	)
Other		(484	)		74			76			-			(334	)
Net Cash Used In Investing Activities		(23,383	)		(2,871	)		1,650			(5,065	)		(29,669	)
Cash Flow From Financing Activities
Long-term debt repayment		(81,575	)		-			-			-			(81,575	)
Short-term debt borrowings - net		-			-			16,673			-			16,673
Bank overdrafts		(1,979	)		-			-			-			(1,979	)
Proceeds from stock options exercised		10,367			-			-			-			10,367
Excess tax benefit on stock options exercised		5,509			-			-			-			5,509
Purchase of treasury stock		(246	)		-			-			-			(246	)
Payment of cash dividends		(14,464	)		(20,000	)		(4,393	)		24,393			(14,464	)
Intercompany financing		-			-			(4,165	)		4,165			-
Net Cash Used In (Provided by) Financing Activities		(82,388	)		(20,000	)		8,115			28,558			(65,715	)
Effect of exchange rate changes on cash and cash equivalents		-			-			4,135			-			4,135
Net Change in Cash and Cash Equivalents		70,258			520			(2,768	)		-			68,010
Cash and Cash Equivalents at Beginning Of Period		22,111			20,302			68,063			-			110,476
Cash and Cash Equivalents at End Of Period	$	92,369		$	20,822		$	65,295		$	-		$	178,486

	For the Nine Months Ended September 29, 2006
				Guarantor			Non-Guarantor						Total
	Parent			Subsidiaries			Subsidiaries			Eliminations			Consolidated
Cash Flow From Operating Activities
Net Income	$	116,529		$	48,010		$	20,771		$	(70,293	)	$	115,017
Adjustments to reconcile net income to net cash provided by operating activities:
Depreciation and amortization		29,955			2,592			5,595						38,142
Equity in earnings of affiliates		(70,681	)		-			(3,377	)		68,781			(5,277	)
Distributions from affiliates		24,006			-			3,002			(22,002	)		5,006
Deferred income taxes		16,362			-			(2,228	)		-			14,134
Asset impairment charges and other asset write-offs		1,220			-			2,622			-			3,842
Non cash compensation expense		7,761			-			-			-			7,761
Unrealized foreign exchange gain		(700	)		-			(859	)		-			(1,559	)
Other		(12	)		-			174			-			162
Change in assets and liabilities:														-
Accounts receivable		(14,582	)		(153	)		(16,592	)		-			(31,327	)
Inventories		(11,838	)		664			(13,806	)		2,362			(22,618	)
Prepaid expenses		2,535			-			834			-			3,369
Accounts payable and accrued expenses		(6,676	)		(285	)		643			-			(6,318	)
Income taxes payable		(4,927	)		3,394			1,151			(850	)		(1,232	)
Excess tax benefit on stock options exercised		(5,443	)		-			-			-			(5,443	)
Intercompany activity		27,668			(27,668	)		-			-			-
Other liabilities		(3,737	)		22			(654	)		-			(4,369	)
Net Cash Provided By Operating Activities		107,440			26,576			(2,724	)		(22,002	)		109,290
Cash Flow From Investing Activities
Additions to property, plant and equipment		(25,395	)		(5,210	)		(2,595	)		-			(33,200	)
Acquisitions (net of cash acquired)		(337,560	)		-			(88	)		-			(337,648	)
Intercompany Investing		3,995			-			-			(3,995	)		-
Return of capital from equity affiliates		1,043			-			1,043			(1,043	)		1,043
Proceeds from note receivable		1,150			-			-			-			1,150
Contingent acquisition payments		(1,396	)		-			-						(1,396	)
Other		178			-			(309	)		-			(131	)
Net Cash Used In Investing Activities		(357,985	)		(5,210	)		(1,949	)		(5,038	)		(370,182	)
Cash Flow From Financing Activities
Long-term debt repayment		(22,204	)		-			(980	)		-			(23,184	)
Long-term debt Borrowings - net		250,000			-			-			-			250,000
Short-term debt borrowings - net		-			-			2,082			-			2,082
Bank overdrafts		(2,985	)		-			-			-			(2,985	)
Proceeds from stock options exercised		9,667			-			-			-			9,667
Excess tax benefit on stock options exercised		5,443			-			-			-			5,443
Payment of cash dividends		(12,297	)		(19,000	)		(4,045	)		23,045			(12,297	)
Intercompany financing		-			-			(3,995	)		3,995			-
Deferred financing costs		(2,019	)		-			-			-			(2,019	)
Net Cash Used In (Provided by) Financing Activities		225,605			(19,000	)		(6,938	)		27,040			226,707
Effect of exchange rate changes on cash and cash equivalents		-			-			3,320						3,320
Net Change in Cash and Cash Equivalents		(24,940	)		2,366			(8,291	)		-			(30,865	)
Cash and Cash Equivalents at Beginning Of Period		48,809			17,110			60,759						126,678
Cash and Cash Equivalents at End Of Period	$	23,869		$	19,476		$	52,468		$	-		$	95,813