SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 4720

         November 3, 2009

Robert V. Cuddihy, Jr.
Chief Operating Officer
The Quigley Corporation
Kells Building
621 Shady Retreat Road
P.O. Box 1349
Doylestown, PA 18901

Re:    The Quigley Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2008
 Filed March 9, 2009
          File Number:  000-21617

Dear Mr. Cuddihy:

  We have reviewed your October 15, 2009 response to our October 5, 2009 letter
and have the following comments.  In our comments, we ask you to provide us with
information to better understand your disc losure.  Where a comment requests you to
revise disclosure, the information you provide should show us what the revised disclosure
will look like and identify the annual or quart erly filing, as applicable, in which you
intend to first include it.  If you do not believe that revi sed disclosure is necessary,
explain the reason in your res ponse.  After reviewing the information provided, we may
raise additional comments and/or request that you amend the above filings.

Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
Critical Accounting Estimates, page 27
 1. Please refer to your response to prior co mment one.  Please revise your proposed
disclosure to quantify each component of the $586,528 portion and the $544,911
portion of the 2008 return provision.  It appe ars that both amounts include returns due
to discontinued products.  The $586,528 portion includes an estimate for returns due
to expired products and an estimate of re turns for discontinued product due to poor
retail sell through.  The $544,911 is mainly due to discontinued products.
 2. Please refer to your response to prior comme nt two.  As it appears that a material
amount of the current year pr ovision was attributable to a change in return estimate
for prior period sales,  please revise your  roll-forward schedule on page 28 to

Robert V. Cuddihy, Jr.
The Quigley Corporation
November 3, 2009
Page 2
separately disclose the amount of the provi sion due to current year sales and prior
period sales.  In assessing ma teriality, we believe that consideration should be given
to the effect on loss from continuing operations before taxes for the periods presented.
 Item 8.  Financial Statements and Supplementary Data

Consolidated Financial Statements
Consolidated Statements of Cash Flows, page F-4
 3. Please refer to the revised Statements of Ca sh Flows for the three year fiscal period
ended December 31, 2008 and the quarterl y period ended March 31, 2008 in your
response to prior comment three.  It is  not clear whether operating, investing and
financing activities related to the discontinue d operations for each period is presented
in their respective categories,  particularly given that you now have included cash and
cash equivalents of discontinue d operations at the bottom of  the statements of cash
flows as part of a reconciliation of be ginning cash and cash equivalents to ending
cash and cash equivalents.  Please revise to  appropriately classi fy operating, investing
and financing activities related to the di scontinued operations or tell us how your
presentation complies with SFAS 95.

* * * *

 Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Pl ease furnish a cover le tter with your response
that keys your response to our comments.  De tailed cover letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

Please contact Dana Hartz, Staff Account ant, at (202) 551-3648 or Don Abbott,
Review Accountant, at (202) 551-3608 if  you have any questions regarding the
processing of your response as well as any que stions regarding the comments.  In this
regard, do not hesitate to contact me, at (202) 551-3679.

        S i n c e r e l y ,

        J i m  B .  R o s e n b e r g
Senior Assistant Chief
Accountant