April 5, 2006

VIA EDGAR & FEDEX

Mr. Michael Fay
Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
100 F Street N.E.
Washington, DC   20549-3561


Re:      The Topps Company, Inc.
         File No. 0-15817
         Form 10-K for the fiscal year ended February 26, 2005


Dear Mr. Fay:

On behalf of The Topps Company,  Inc. (the "Company"),  we are responding to the
comments of the staff of the  Securities and Exchange  Commission  pertaining to
the Company's  Form 10-K for the year ended  February 26, 2005 (the "Form 10-K")
as contained in your letter dated March 23, 2006 (the "Comment Letter").


Form 10-K for the fiscal year ended February 26, 2005
- -----------------------------------------------------

Note 16:  Segment and Geographic Information

     1.   We note your response to prior comment 7. Although we understand  that
          you believe that  disclosing  product level revenue on a regular basis
          may put the Company at a significant disadvantage, the FASB considered
          this  matter  and  decided  that  a  competitive-harm   exemption  was
          inappropriate in its final  deliberations of SFAS No. 131, as cited in
          paragraph 109-111 of the standard.

          Therefore,  we  continue  to  believe  that  the  amounts  of  revenue
          generated  for  each  significant   product  should  be  disclosed  in
          accordance  with paragraph 37 of SFAF No. 131,  especially in light of
          the erratic or  unpredictable  nature of the  Entertainment  reporting
          unit and the importance of understanding key trends and performance in
          major product groups. Please revise accordingly in future filings.

Response:
- --------

In its  future  filings,  the  Company  will  disclose  the  amounts  of revenue
generated  for each  significant  product or  product  line in  accordance  with
paragraph 37 of SFAS No. 131.


Final Statement
- ---------------

The Company  acknowledges  responsibility  for all  information  provided to the
investment  community in our public filings in general.  We further  acknowledge
that comments from the SEC staff or changes to Company  disclosures  in response
to SEC staff comments in the filings do not prevent the  Commission  from taking
any action with respect to the filings and that 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.



Sincerely,



s/ Catherine Jessup
- -------------------
Catherine Jessup
Vice President, CFO and Treasurer
The Topps Company, Inc.