Mail Stop 3561

				April 7, 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 response to our prior comment on the above
referenced filing as set forth in your letter dated April 6, 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 one of our letter dated March
30,
2006.  We do not concur with your conclusion reached with respect
to
only disclosing three reportable segments, namely Wholesale
Apparel
and Related Products, Retail Apparel and Related Products, and
Calvin
Klein Licensing.  Based on our quantitative review of the actual
revenues and gross margins presented for your operating segments
it
would appear that several of your operating segments do not have
similar economic characteristics.  Several of your material
operating
segments demonstrated different trends in both sales and gross
margins.  Please note the following examples:

Sales from your dress shirt business have been relatively flat
when
compared with your other wholesale operating segments.  For
example,
we note Izod Sport experienced sales increases of 15.79% in 2003
when
compared with 2002, and 8.6% in 2004 when compared to 2003.
Furthermore, Izod Sport experienced a 16.84% increase in gross
margin
in 2004 when compared to 2003.  Furthermore, we understand that
dress
versus casual trends could impact both sales and gross margins.

We have also observed decreasing sales trends in both your Van
Heusen
Retail and Bass Retail operating segments.   As you are aware,
your
Van Heusen Retail operating segment experienced a 4.03% decrease
in
sales in 2003 as compared to 2002, and remained relatively flat in
2004 when compared to 2003.  The Bass Retail operating segment
sales
decreased 5.34% in 2003 when compared to 2002, and decreased 4.63%
in
2004 when compared to 2003.  We have also noticed material changes
in
the gross margins for these operating segments for the years ended
2004, 2003, and 2002.

It appears that you have additional reportable segments.  In your
response, please provide us with additional analysis in support of
the aggregation of the Dress Shirt Group with other apparel
operations. It does not appear appropriate to aggregate Izod Sport
with other apparel operations based upon recent trends in the Izod
business.  It does not appear appropriate to aggregate Bass or Van
Heusen retail operations with other retail operations due to the
size
of these businesses, their economic trends and the fact that Bass
primarily sells shoes.

	```````````````````````````````````````````````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


Mr. Vincent Russo
Phillips-Van Heusen Corporation
April 7, 2006
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