CASTLE BRANDS INC. 570 Lexington Avenue, 29th Floor New York, NY 10022 April 5, 2006 Via Fax and Edgar Submission Securities and Exchange Commission United States Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Castle Brands Inc. Registration Statement On Form S-1 (File No. 333-128676) ----------------------------------------- Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Castle Brands Inc. (the "Company") respectfully requests that the effective date of the above-referenced Registration Statement be accelerated so that the Registration Statement may become effective at 4:00 p.m. on April 5, 2006 or as soon as practicable thereafter. The Company acknowledges that: o should the Securities and Exchange Commission (the "Commission") or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; o the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and o the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. CASTLE BRANDS INC. By: /s/ Mark Andrews ____________________________________ Mark Andrews Chairman and Chief Executive Officer