Mail Stop 3561

                              April 14, 2006


Mr. Franklin N. Saxon
President and Chief Operating Officer
Culp, Inc.
1823 Eastchester Drive
Hight Point, NC 27265

      Re:	Culp, Inc.
      Form 10-KSB for the Fiscal Year Ended May 1, 2005
      Filed July 12, 2005
      File No. 1-12597

Dear Mr. Saxon:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related discourses and do not intend to expand our review to other
portions of your documents.  Please provide a written response to
our
comments.  Please be as detailed as necessary in your explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	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 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 May 1, 2005

1. Unless otherwise indicated, where a comment below requests
additional disclosures or other revisions to be made, these
revisions
should be included in your future filings, as applicable.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 19

Commitments, page 30

2. Please consider revising your contractual obligations table to
include estimated interest payments on your long term debt.
Because
the table is aimed at increasing transparency of cash flow, we
believe these payments should be included in the table.  If you
choose not to include these payments, a footnote to the table
should
clearly identify the excluded item and provide any additional
information that is material to understanding your cash
requirements.

Consolidated Financial Statements and Supplementary Data, page 35

Notes to Consolidated Financial Statements, page 42

3.  Accounts Receivable, page 50

3. Please present the activity in your reserve for returns and
allowances and discounts.  Alternatively, you may provide such
disclosure in Schedule II - Valuation and Qualifying Accounts.
Refer
to Rules 5-04 and 12-09 of Regulation S-X.

Exhibits 31(a) and 31(b)

4. Please confirm to us that the inclusion of the titles of the
Chairman and Chief Executive Officer and President and Chief
Operating Officer in the introductory paragraphs was not intended
to
limit the capacity in which such individuals provided the
certifications.  In future filings please omit the titles in the
introductory paragraph to conform to the format provided in Item
601(b)(31)(i) of Regulation S-K.  Also refer to Question 11 of the
Staff`s Frequently Asked Questions regarding the Sarbanes-Oxley
Act
of 2002 issued in November 2002 and available on our website at
www.sec.gov.


*      *      *      *      *

      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 any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your response to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing 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 filing;

* 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 Yong Kim at (202) 551-3323 if you have
any
questions regarding these comments.  Please contact me at (202)
551-
3716 with any other questions.

									Sincerely,



									William Choi
									Branch Chief

Mr. Saxon
Culp, Inc.
April 14, 2006
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

         DIVISION OF
CORPORATION FINANCE