PHOENIX FOOTWEAR GROUP, INC.
5840 El Camino Real, Suite 106
Carlsbad, CA 92008
January 10, 2011
Via EDGAR
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Attention: John Reynolds, Assistant Director
| Re: | Phoenix Footwear Group, Inc. |
| Form 10-K for Fiscal Year Ended January 2, 2010 |
| Filed on March 31, 2010 |
| File No. 001-31309 |
Dear Mr. Reynolds:
We are writing in response to the comments of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) contained in the letter dated, and received by telecopy on December 23, 2010, related to the Company’s Form 10-K for the fiscal year ended January 2, 2010. This confirms the discussion today of our counsel Timothy Condon, Esq., of Woods Oviatt Gilman LLP, with Damon Culbert of your office. We respectfully request an extension of time to respond to the Staff’s comment letter from today’s deadline until Friday January 14, 2011.
Please contact me if you have any further questions. Thank you for your courtesies in this matter.
Sincerely,
PHOENIX FOOTWEAR GROUP, INC.
/s/ James R. Riedman
James R. Riedman
Chief Executive Officer
