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                         Bernard Chaus, Inc. letterhead

Mr. George Ohsiek, Jr., Branch Chief                              March 14, 2005
Division of Corporation Finance
Securities Exchange Commission
Washington, D.C. 20549

                       Re: Bernard Chaus, Inc. (the "Company")
                           Form 10-K for the year ended June 30, 2004
                           Filed September 28, 2004

Dear Mr. Ohsiek:

We are in receipt of your letter dated February 16, 2005 with regard to the
Company's Form 10-K for the fiscal year ended June 30, 2004. The following are
our responses to the comments:

General

1.   Where a comment below requests additional disclosures or other revisions to
     be made, these revisions should be included in your future periodic
     filings, as applicable.

     The Company will include the requested additional disclosure or other
     revisions in future periodic filings.

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations

Results of Operations, page 10

2.   Please expand your discussion of consolidated gross margin for the years
     presented to include, where practicable, quantification and analysis of the
     factors you identify as contributing to changes in gross margin. For
     example, you refer to S.L. Danielle and Cynthia Steffe divisions as reasons
     for increase in gross profit dollars but do not quantify amounts.
     Similarly, you attribute the decline in gross margin percentage to the
     "Chaus" product lines sold but do not provide a discussion or analysis of
     this factor to allow a reader to understand the significance of sales mix
     on gross margin for the period, or the specific reasons why sales mix
     resulted in a decline in gross margin. See Item 303(a) of Regulation S-K
     and SEC Release No. 33-8350.

     The Company will include an expanded discussion of gross margin in future
     periodic filings as requested.

                                      -2-

Financial Condition, Liquidity and Capital Resources, page 12

3.   Please revise your Management's Discussion and Analysis to explain why
     there were material changes in your accounts receivable and payable. Expand
     your discussion of changes in operating cash flows on page 12 to indicate
     if management expects operating cash flows in 2005 to resemble 2004. See
     item 303 of Regulation S-K.

     The increase in the Company's accounts receivable of $9.0 million was
     primarily due to a change in the mix of customers, relative to the prior
     year, to a mix consisting of customers with typically longer payment terms,
     such as discounters. To a lesser extent, the increase also resulted from an
     increase in sales of $6.4 million during the fourth quarter of fiscal 2004
     as compared to the same quarter in fiscal 2003. The decrease in accounts
     payable of $4.8 million was primarily attributable to lower inventories in
     fiscal 2004 as compared to fiscal 2003 and the timing of payment for
     purchases of inventory. The decrease was also due to a change in the mix of
     suppliers, with the Company purchasing higher levels of raw materials than
     in prior periods, which require earlier payments. A greater portion of the
     Company's inventory purchases requires the Company to purchase raw
     materials. The Company does not currently anticipate that these changes in
     accounts receivable or accounts payable will adversely affect its cash
     flows for the balance of fiscal 2005. The Company will explain any material
     changes in its accounts receivable and payable in future filings. The
     Company will also expand its discussion of changes in operating cash flows
     in future periodic filings, as appropriate, to discuss the impact of any
     such changes on its cash flows.

Notes To Consolidated Financial Statements

General

4.   Please tell us whether you offer any customer incentives in connection with
     the purchase or promotion of your products, such as discounts, coupons,
     rebates, slotting fees, payments under buydown agreements, and other
     consideration. If so, please disclose the statement of income line item in
     which each of these types of consideration is included. Additionally,
     disclose how you account for your allowances related to your volume-based
     programs. See EITF 00-22 and 01-09.

     The Company offers trade discounts and considers these discounts, as well
     as allowances for returns, allowable customer markdowns and operational
     charge backs in its revenue recognition accounting. As disclosed in Note 2,
     Summary of Significant Accounting Policies - Revenue Recognition and
     Accounts Receivable, these items are recorded as a reduction of net
     revenues when sales are recorded and are based upon seasonal negotiations,
     historical deduction trends, net of expected recoveries and the evaluation
     of current market conditions.

                                      -3-

     The Company also offers a minor amount of cooperative advertising
     allowances (approximately $356,000, $316,000 and $616,000 for fiscal years
     2004, 2003 and 2002, respectively). Cooperative advertising allowances were
     recorded as advertising expenses and were included in selling, general and
     administrative expenses in the period in which the costs were incurred
     because the allowances met the conditions in EITF 01-09. Specifically, the
     Company receives an identifiable benefit (advertising for the Company's
     products) in exchange for the cooperative advertising allowances. That
     benefit is sufficiently separable from the retailer's purchase of the
     Company's products because the Company could have purchased that
     advertising from another party that does not purchase the Company's
     products. Therefore, the first condition of the model is met. The Company
     obtains documentation of all advertising performed that includes the
     Company's products. The second condition of the model is also met because
     an estimate of the fair value of the advertising benefit is made. As a
     result, because that fair value is equal to or greater than the allowance,
     the allowance should be characterized as a cost incurred when recognized in
     the Company's statement of operations.

     The Company will disclose the amount of cooperative advertising allowances
     included in the statements of operations in future periodic filings. The
     Company does not offer coupons, rebates, slotting fees, payments under buy
     down agreements, or other consideration. The Company does not offer
     allowances for volume-based programs.

Note 2. Significant Accounting Policies

Credit Terms, page F-7

5.   Please revise to clarify whether you account for your receivables that are
     factored with recourse, as a sale pursuant to paragraph 9 of SFAS 140 or a
     secured borrowing. Also tell us how cash flows related to this arrangement
     are recorded on the statements of cash flows.

     As disclosed in Note 2, Significant Accounting Policies - Credit Terms, "At
     June 30, 2004, approximately 95% of the Company's accounts receivable was
     non factored." "Receivables related to sales of Cynthia Steffe product
     lines continue to be factored." We do not have any receivables that are
     factored with recourse.

     As discussed in SFAS 140, paragraph 112, "Factoring arrangements are a
     means of discounting accounts receivable on a nonrecourse, notification
     basis. Accounts receivable are sold outright, usually to a transferee (the
     factor) that assumes the full risk of collection, without recourse to the
     transferor in the event of a loss. Debtors are directed to send payments to
     the transferee. Factoring arrangements that meet the criteria in paragraph
     9 shall be accounted for as sales of financial assets because the
     transferor surrenders control over the receivables to the factor."

     We considered the guidance in SFAS 140, including the criteria in
     paragraphs 9 and 112, and concluded that the Company's factoring
     arrangement with CIT should be accounted for as a sale. Our footnote
     disclosures included information about the amount due from

                                      -4-

     factor at June 30, 2004. We will clarify our disclosures with respect to
     accounts receivable that are factored in our future period filings and will
     include "Due from factor" as a separate line item in our consolidated
     balance sheets and cash flow statements.

     Cash flows related to the factoring arrangement are recorded in the
     statements of cash flows in operating activities in changes in accounts
     receivable in accordance with SFAS 95.

Inventories, page F-8

6.   We note a substantial amount of your products are manufactured overseas and
     merchandise in transit is included in inventory. Please expand your policy
     to state when you record inventory and take title and assume risk of loss.

     The majority of the Company's inventory purchases are shipped FOB shipping
     point from the Company's suppliers. The Company takes title and assumes the
     risk of loss when the merchandise is received at the boat or airplane
     overseas. The Company records inventory at the point of such receipt at the
     boat or airplane overseas. The Company will expand its disclosure of this
     policy to state when we record inventory and take title and assume risk of
     loss in future periodic filings.

Shipping and handling costs, page F-10

7.   Please tell us if you charge customers for shipping and handling costs. If
     so, disclose where you record amounts billed to customers. See paragraph 5
     of EITF 00-10.

     For the majority of its business, the Company does not charge customers for
     shipping and handling costs. In fiscal 2004 and prior years, shipping and
     handling costs that were charged to customers were deminimus (i.e. $39,000
     or 0.025% of net revenues for fiscal 2004; $15,000 or 0.01% of net revenues
     for fiscal 2003; and $32,000 or 0.02% of net revenues for fiscal 2002) and
     were recorded as a reduction to the Company's shipping and handling costs,
     a component of selling, general and administrative expenses, at the time of
     billing to the customer. On a prospective basis, we will classify shipping
     and handling costs charged to customers as a component of net revenues in
     accordance with EITF 00-10. We will also disclose the classification of
     shipping and handling revenue in future periodic filings.

Note 3. Inventories, page F-11

8.   Please be advised that the inventory write down due to obsolescence
     establishes a new cost basis and should not be presented as a reserve. See
     Chapter 4, footnote 2, of ARB 43 and SAB Topic 5:BB. We assume the company
     is presenting the reserve for informational purposes only and that you do
     not increase the cost basis of inventory items after a

                                      -5-

     reserve has been recorded. Please confirm whether our understanding is
     correct and clarify in future filings. Additionally, if the sale of
     inventory previously written-down resulted in the recognition of gross
     margin in excess of your typical margin and the effects were material to
     reported results of operations, please provide appropriate MD&A disclosure.

     As disclosed in Note 2, Summary of Significant Accounting Policies -
     Inventories, the Company establishes reserves for slow moving and aged
     merchandise based on historical experience and current product demand. Once
     the reserves are established, the Company does not thereafter increase the
     cost basis of the inventory. We will clarify our inventory disclosures in
     future periodic filings. The Company will disclose inventory at its new
     adjusted cost basis, rather than at its initial cost basis, and eliminate
     the presentation of reserves in future periodic filings.

     The Company has not recognized any material gains in gross margin on the
     sale of inventory that was previously written down during fiscal years
     2004, 2003 or 2002. The Company will include appropriate MD&A disclosures
     in future periodic filings of any material gains in gross margin to the
     extent that such gains are realized in future periods.

Note 4. Fixed Assets, page F-11

9.   Please breakout computer hardware and software line items in this table to
     match the disclosure of the useful lives of our fixed assets on page F-10.

     We will revise our fixed assets table to breakout computer hardware and
     software as separate line items as detailed below and will include the
     table in this format in future periodic filings.

     (In thousands)                                 June 30, 2004  June 30, 2003

     Computer hardware and software                       $ 4,126        $ 3,237
     Furniture and equipment                               10,224         10,151
     Leasehold improvements                                10,494         10,025
                                                           ------         ------
                                                           24,844         23,413
     Less: Accumulated depreciation and amortization       20,632         19,621
                                                           ------         ------
     Fixed assets - net                                   $ 4,212        $ 3,792
                                                          =======        =======

Note 5. Income Taxes, page F-12

10.  Please disclose the portion of your operating loss carry-forwards related
     to the exercise of nonqualified stock options. See paragraph 48 of SFAS
     109.

     None of the operating loss carry-forwards relate to the exercise of
     nonqualified stock options.

                                    * * * * *

                                                 Very truly yours,

                                                 /s/ Barton Heminover
                                                 -----------------------
                                                 Barton Heminover
                                                 Chief Financial Officer