Via Facsimile and U.S. Mail
Mail Stop 6010


October 7, 2005


Mr. Harvey Kamil
Chief Financial Officer
NBTY, Inc.
90 Orville Drive
Bohemia, NY  11716

Re:	NBTY, Inc.
	Form 10-K for the fiscal year ended September 30, 2004
	File No. 1-31788

Dear Mr. Kamil:

      We have reviewed your September 9, 2005 response to our July
25, 2005 comment letter and have the following comments. In our
comments, we ask you to provide us with information so we may
better
understand your disclosure.

	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.


Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Critical Accounting Policies and Estimates

Revenue Recognition, page 23
1. Please refer to your response to prior comment one.  Please
explain to us why there are no deductions in your rollforward
schedule of the promotional program incentive accrual.
Additionally,
we believe the promotional program incentive accrual rollforward
schedule would be important to investors and this proposed
disclosure
should also be included within Management`s Discussion and
Analysis.
Please revise your proposed disclosures, accordingly.

2. Please tell us the nature of the amounts charged to other
accounts
in the promotional program incentive accrual in fiscal year 2003.
3. Please confirm that you will include a discussion within
Management`s Discussion and Analysis to disclose why you do not
have
the ability to track returns by fiscal period as outlined in your
response dated September 8, 2005.

Liquidity and Capital Resources

EBITDA, page 36-37
4. We have read your response to prior comments two and three;
however, we continue to believe that you have not met the burden
of
demonstrating the usefulness of any financial measure that
excludes
recurring items.  Answer 10 in the Non-GAAP FAQ allows the use of
EBITDA in certain circumstances as a liquidity measure if this
measure is contained in a material debt agreement; however, it
continues to state that discussion of the non-GAAP financial
measure
for other purposes would not be permitted.  The discussion of
EBITDA
as a liquidity measure as it relates to your credit agreements
would
be allowed. Please tell us how you plan to delete EBITDA as a
supplementary non-GAAP operating performance measure in your
filings
or provide additional supplemental information to demonstrate why
these measures provide useful information to investors.

*    *    *    *

      Please respond to the comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your response to our comments and provides requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.
Please
understand that we may have additional comments after reviewing
responses to our comments.

      You may contact Todd Sherman, Staff Accountant, at 202-551-
3665
or Don Abbott, Senior Accountant, at 202-551-3608 if you have
questions regarding the comment.  In this regard, do not hesitate
to
contact me, at (202) 551-3679.

	Sincerely,


								Jim B. Rosenberg
							Senior Assistant Chief
Accountant
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Harvey Kamil
NBTY, Inc.
October 7, 2005
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