SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0303

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3628

April 24, 2009

By Facsimile and U.S. Mail

Aron Izower, Esq. Reed Smith LLP 599 Lexington Avenue 22
nd Floor
New York, NY 10012
Re:   Quigley Corporation  Revised Proxy Statement on Schedule 14A  filed by Ted Karkus et al.
Filed April 21, 2009 File No. 0-21617

Dear Mr. Izower:

We have reviewed your  filings and have the following co mments.  Where indicated, we
think you should revise your document in response to these comments.  If you disagree, we will
consider your explanation as to why a comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessa ry in your explanation.  In some  of our comments, we may ask
you to provide us with supplemental informati on so we may better understand your disclosure.
After reviewing this information, we ma y or may not raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filings.  We look forward to working with  you in these respects.  We welcome any
questions you may have about our comments or any other aspect of our review.  Feel free to call
us at the telephone numbers listed  at the end of this letter.
 Schedule 14A

1. We note your response to comment one in our letter dated April 16, 2009.  Please advise us
as to how your notice of intern et availability complies with the requirements in Rule 14a-
16.  For example, it does not appear to contai n all of the information required by Rule 14a-
16(c)(1) and contains supporting statements when Rule 14a-16(c)(3) specif ically states that
no supporting statements be included.  Please refer to Rule 14a-16 and SEC Release No.
34-56135 in your analysis.

Aron Izower, Esq.
Quigley Corporation April 24, 2009 Page 2   Reasons for the Solicitation, page 2

2. We note your response to comment six in our  letter dated April 16, 2009.  Please revise
your disclosure to include the support for your statements.
3. We note that the participants collectively own over 10% of th e shares outstanding.  Please
revise to include the information requ ired by Item 405 of Regulation S-K and
corresponding Item 7(b) of Schedule 14A.
 Proposal One—Election of  Directors, page 4

4. We note your statement that one or more Shareholder Nominees qualify as an audit
committee financial expert.  Please revi se to identify these individuals.
 What is a quorum, page 11

5. We note your response to comment 12 in our le tter dated April 16, 2009.  Please revise to
clearly state the effect of broker non-votes and abstentions on the quorum requirement.

Please direct any questions to me at ( 202) 551-3411.  You may also contact me via
facsimile at (202) 772-9203.  Please send all correspondence to us at the following ZIP code:  20549-3628.
                               Sincerely,
                                      Peggy Kim         S p e c i a l  C o u n s e l          Office of Mergers & Acquisitions