Mail Stop 03-08
								May 25, 2005

Mr. John W. Feray
Chief Accounting Officer
Haggar Corp.
11511 Luna Road
Dallas, Texas 75234

	RE:	Haggar Corp.
		Form 10-K for the Fiscal Year Ended September 30, 2004
		Filed December 10, 2004
      Form 10-Q for the Fiscal Quarter Ended December 31, 2004
      Filed February 9, 2005
		File No. 0-20850

Dear Mr. Feray:

	We have reviewed the responses in your letter dated May 10,
2005
and have the following additional comments.  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.

Form 10-K for the Fiscal Year Ended September 30, 2004

1. We have reviewed your response to comment 6 in our letter dated
April 18, 2005 and note your proposed disclosure that "[t]he
Company
records its best estimate of margin allowances, returns, co-
operative
advertising and rebates at the later of the date at which the
related
revenue is recognized or the date at which the allowance is
offered
to the customer."   We are unclear as to why returns are
recognized
at the later of the date at which the related revenue is
recognized
or the date at which the allowance is offered.  Please clarify the
disclosure accordingly.  Please also revise the disclosure to
clarify
the circumstances under which margin allowances, cooperative
advertising allowances, and rebates are offered to customers at
dates
other than the time of sale and revenue recognition.  Show us how
the
revised disclosure will read.

Form 10-Q for the Fiscal Quarter Ended December 31, 2004

Item 4.  Controls and Procedures, page 21

2. We have reviewed your response to comment 14 in our letter
dated
April 18, 2005.  Please provide footnote disclosure in your next
filing on Form 10-Q regarding the error corrections you recorded
in
the fiscal quarter ended December 31, 2004.  The disclosure should
indicate the nature of each of the errors you identified, how and
when you discovered the errors, the individual and net impact of
the
errors on your historical financial statements, and the individual
and net impact of correcting the errors on the year to date
results
of operations.  Refer to paragraph 37 of APB 20.  The disclosure
should also indicate that management has not restated the
historical
results because it believes the errors to be quantitatively and
qualitatively immaterial on an individual and net basis.  Please
show
us how the disclosures will read.

      As appropriate, 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 supplemental information.  Detailed letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

		You may contact Yong Kim at (202) 551-3323 or Robyn
Manuel
at (202) 551-3823 if you have any questions regarding these
comments.
Please contact me at (202) 551-3843 with any other questions.


							Sincerely,



							George F. Ohsiek, Jr.
							Branch Chief



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Mr. John W. Feray
Haggar Corp.
May 25, 2005
Page 2