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                             THE QUIGLEY CORPORATION
                                 KELLS BUILDING
                             621 SHADY RETREAT ROAD
                         DOYLESTOWN, PENNSYLVANIA 18901
                                TEL. 215-345-0919
                                FAX 215-345-5920

August 29, 2005

Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549-601
Attention: Jim B. Rosenberg

Re:  The Quigley Corporation ("TQC")
     Form 10-K for the fiscal year ended December 31, 2004
     File No. 000-21617
     -----------------------------------------------------

Ladies and Gentlemen:

We acknowledge receipt of the letter of comment dated August 4, 2005 from the
Securities and Exchange Commission (the "Commission Letter"). We have reviewed
the letter with our auditors and the following reflect our responses to the
Commission Letter. The section and page number references below refer to our
annual report on Form 10-K for the fiscal year ended December 31, 2004 filed
with the Securities and Exchange Commission on March 31, 2005. The responses are
numbered to coincide with the numbering of the comments in the Commission
Letter.

CRITICAL ACCOUNTING POLICIES, PAGE 18

1.   WE ACKNOWLEDGE YOUR REVENUE  RECOGNITION  POLICY AS NOTED HEREIN AND WITHIN
     YOUR "SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES" IN THE ACCOMPANYING NOTES
     TO YOUR CONSOLIDATED FINANCIAL STATEMENTS.  WE BELIEVE THAT YOUR DISCLOSURE
     RELATED TO ESTIMATES OF ITEMS THAT REDUCE YOUR GROSS REVENUE, SUCH AS SALES
     RETURNS AND  ALLOWANCES,  COULD BE DEFINED AND IMPROVED.  PLEASE PROVIDE US
     WITH THE FOLLOWING INFORMATION IN A DISCLOSURE-TYPE FORMAT:

     a.)  THE TYPE AND AMOUNT OF EACH ACCRUAL AT THE BALANCE SHEET DATES AND THE
          EFFECT THAT COULD RESULT FROM USING OTHER REASONABLY LIKELY ASSUMPTION
          THAN THOSE UPON WHICH YOU CURRENTLY RELY. FOR EXAMPLE,  PLEASE PROVIDE
          A RANGE OF REASONABLY  LIKELY  AMOUNTS OR ANOTHER TYPE OF  SENSITIVITY
          ANALYSIS.

TQC RESPONSE

Sales returns and  allowances,  cash discounts and  reductions  for  cooperative
advertising  are the  types of  accruals  provided  for in the  period  that the
related  sales  are  recorded.  Provisions  for  these  reserves  are  based  on
historical experience and the monitoring of current occurrences and developments
that could affect the expected  sales  returns or other  adjustments  within the
industry   that  the  products   are  sold.   Specific   events,   such  as  the
discontinuation  of a product,  would be added to the normal  provisions for any
fiscal periods presented.

Using the only other reasonable assumption for a sensitivity  analysis,  such as
the use of  average  industry  standards  for such  adjustments,  instead of the
foregoing  method to estimate  sales returns and  allowances  and cash discounts
(there is no variation  for cash  discounts in the  sensitivity  analysis),  but
excluding  reductions for  cooperative  advertising,  related to the sales would
increase  net sales by  approximately  $432,000,  $241,000  and $572,000 for the
fiscal  years  ended  December  31,  2004,  2003 and  2002,  respectively,  and,
accordingly,  reduce  related  balance  sheet  accruals at December 31, 2004 and
2003,  respectively.  A  1%  increase  or  decrease  variation  for  cooperative
advertising in cold remedy products would thereby change net sales approximately
$279,000,  $241,000 and  $175,000 for the fiscal years ended  December 31, 2004,
2003 and 2002,  respectively,  and,  accordingly,  change related  balance sheet
accruals at December 31, 2004 and 2003, respectively.

The Cold Remedy Segment  includes a provision to reduce accounts  receivable for
sales  returns  and  allowances  and cash  discounts  or is  included in current
liabilities  for  cooperative  advertising at December 31, 2004 and 2003.  These
provisions  were for  sales  returns  and  allowances,  including  the  specific
provision of $626,000 related to the  discontinuation  of the Cold-Eeze(R)  Cold
Remedy Nasal Spray product in 2004, of  $1,048,000  and $343,000,  respectively;
cash  discounts  of  $92,000  and  $115,000,   respectively;   and   cooperative
advertising of $743,000 and $1,295,000, respectively.

The  Health  and  Wellness  Segment  includes  a  provision  to reduce  accounts
receivable at December 31, 2004 and 2003 for returns and  adjustments of $61,000
and $61,000, respectively.

     b.)  THE FACTORS  THAT YOU CONSIDER IN  ESTIMATING  EACH  ACCRUAL,  SUCH AS
          HISTORICAL  PRODUCT RETURNS,  LEVELS OF INVENTORY IN YOUR DISTRIBUTION
          CHANNELS;  ESTIMATED REMAINING PRODUCT SHELF LIVES; PRICE CHANGES FROM
          COMPETITORS AND INTRODUCTIONS OF NEW PRODUCTS.

TQC RESPONSE

The cold  remedy  product,  Cold-Eeze,  which is offered  in a lozenge,  gum and
tablet form, has been clinically  proven in two  double-blind  studies to reduce
the severity and duration of common cold symptoms. Accordingly, Cold-Eeze offers
a significant  advantage over many of its  competitors  in the  over-the-counter
cold-remedy market. Therefore,  additional factors considered in estimating each
accrual  for this  product  are as stated in TQC  RESPONSE to 1. (a) AND (c) and
since   Cold-Eeze   is  a   "one-of-a-kind"   unique  item  with  very   limited
inconsequential  competitors whereby  competitive price reductions,  promotions,
new items and remaining  shelf life, as the product has no expiration  date, are
not  factors  that  TQC  needs  to  consider  when  estimating  sales  allowance
provisions.  However,  TQC does consider inventory levels at major customers and
third-party consumption data, such as Information Resources, Inc. ("IRI") and/or
Nielsen when estimating sales allowance provisions.

The health and wellness  product  line factors  considered  in  estimating  each
accrual for this product are as stated in TQC RESPONSE to 1. (a) AND (c) and the
particular  methodology  of marketing,  which is direct  selling of  proprietary
products through independent representatives,  adds to the unique nature of such
products.  Currently,  pursuant  to  this  methodology,  returns  are  generally
permitted  within  sixty  days  of  the  sale,  and  other  requirements  of the
agreements with the independent representatives,  which leads to provisions that
represent actual returns and adjustments that are not subject to variations that
could  arise with a greater  time for sales  returns or that are common to other
products or industries.

     c.)  TO THE EXTENT THAT THE INFORMATION YOU CONSIDER IN B. IS QUANTIFIABLE,
          DISCUSS BOTH  QUANTITATIVE  AND QUALITATIVE  FACTORS AND THE EXTENT OF
          AVAILABILITY  AND YOUR USE OF INFORMATION FROM EXTERNAL  SOURCES;  FOR
          EXAMPLE,  END-CUSTOMER  DEMAND DATA COMPARED TO INVENTORY  LEVELS.  IN
          DISCUSSING  YOUR  ESTIMATE  OF  PRODUCT  RETURNS,  PROVIDE  ADDITIONAL
          INFORMATION,  PREFERABLY BY PRODUCT AND IN TABULAR  FORMAT,  REGARDING

                                       2

          THE TOTAL AMOUNT OF PRODUCT IN SALES DOLLARS THAT COULD POTENTIALLY BE
          RETURNED  AS THE MOST RECENT  BALANCE  SHEET  DATE,  DISAGGREGATED  BY
          EXPIRATION PERIOD.

TQC RESPONSE

The qualitative and quantitative  factors considered for any product returns and
adjustments are indicated in TQC RESPONSE to 1.a) AND b).

A tabular format  delineation by specific product for the Cold Remedy Segment is
not provided since Cold-Eeze, which is sold in a lozenge, gum and tablet form is
only one product and represents in excess of 99% of products categorized in this
segment.  A tabular format  delineation  by specific  product for the Health and
Wellness Segment is not provided due to the nature of the proprietary  products,
the limited time for returns and  requirements  as stated in the agreements with
the independent representative of the Health and Wellness Segment along with the
inability to delineate the various product returns and or adjustments as returns
or adjustments are not quantified or recorded by specific product category.

     d.)  IF  APPLICABLE,  DISCUSS ANY SHIPMENTS  MADE AS A RESULT OF INCENTIVES
          AND/OR IN EXCESS OF YOUR CUSTOMERS'  INVENTORY  LEVELS IN THE ORDINARY
          COURSE OF  BUSINESS.  PLEASE ALSO  DISCUSS  YOUR  REVENUE  RECOGNITION
          POLICY FOR SUCH SHIPMENTS.

TQC RESPONSE

In both the Cold Remedy and Health and Wellness Segments, shipments are not made
as a result of incentives in the ordinary  course of business.  Occasionally,  a
new  customer  in the Cold  Remedy  Segment  will be given an  extended  term of
payment  to  60  days  from  31  days  for  only  the  initial  stocking  order.
Additionally,  as the Cold  Remedy  Segment is  seasonal  with the  majority  of
revenues  occurring  in the  fourth  quarter,  customers  will  start  to  build
inventories, based on their prior experiences, modified by published data on the
timing and  quantities  of expected  incidence  of colds by specific  locations,
which is also reviewed as part of the normal  procedures in order fulfillment by
the Company.  As the  foregoing  is not  consequential  or  material,  it is not
specifically considered for sales returns and allowances provisions.

     e.)  A ROLL-FORWARD OF THE LIABILITY FOR EACH ESTIMATE FOR THE PERIODS
               PRESENTED, SHOWING THE FOLLOWING:
               o  BEGINNING BALANCE;
               o  CURRENT PROVISION RELATED TO SALES MADE IN CURRENT PERIOD;
               o  CURRENT PROVISION RELATED TO SALES MADE IN PRIOR PERIODS;
               o  ACTUAL  RETURNS OR CREDITS IN CURRENT  PERIOD RELATED TO SALES
                  MADE IN CURRENT PERIOD;
               o  ACTUAL  RETURNS OR CREDITS IN CURRENT  PERIOD RELATED TO SALES
                  MADE IN PRIOR PERIODS; AND
               o  ENDING BALANCE.

TQC RESPONSE

ACCOUNT - SALES RETURNS & ALLOWANCES                                                     2004               2003
--------------------------------------------------------------------------------     ------------        ----------

Beginning balance                                                                        $403,850           $426,557
Current provision related to sales made in current period*                              1,414,796            937,738
Current provision related to discontinuation of Cold-Eeze nasal spray                     625,756
Current provision related to sales made in prior periods*
Actual returns-credits in current period related to sales made in current period*      (1,335,231)          (960,445)
Actual returns-credits in current period related to sales made in prior period*
                                                                                       ----------           --------
Ending balance                                                                         $1,109,171           $403,850
                                                                                       ==========           ========
* AMOUNTS FOR EACH LINE CATEGORY ARE NOT SPECIFICALLY AVAILABLE

                                       3

ACCOUNT - CASH DISCOUNTS                                                                 2004               2003
--------------------------------------------------------------------------------     ------------        ----------
Beginning balance                                                                        $114,580            $96,961
Current provision related to sales made in current period*                                541,290            471,781
Current provision related to sales made in prior periods*
Actual returns-credits in current period related to sales made in current period*        (563,413)          (454,162)
Actual returns-credits in current period related to sales made in prior period*
                                                                                       ----------           --------
Ending balance                                                                            $92,457           $114,580
                                                                                       ==========           ========
* AMOUNTS FOR EACH LINE CATEGORY ARE NOT SPECIFICALLY AVAILABLE

ACCOUNT - COOPERATIVE ADVERTISING                                                        2004               2003
--------------------------------------------------------------------------------     ------------        ----------
Beginning balance                                                                      $1,294,927           $754,813
Current provision related to sales made in current period*                              2,203,179          2,642,128
Current provision related to sales made in prior periods*
Actual returns-credits in current period related to sales made in current period*      (2,754,724)        (2,102,014)
Actual returns-credits in current period related to sales made in prior period*
                                                                                       ----------           --------
Ending balance                                                                           $743,382         $1,294,927
                                                                                       ==========           ========
* AMOUNTS FOR EACH LINE CATEGORY ARE NOT SPECIFICALLY AVAILABLE

     f.)  FINALLY,  INCLUDE  INFORMATION  REGARDING THE AMOUNT OF AND REASON FOR
          FLUCTUATIONS  WITH RESPECT TO EACH  ITEM/ESTIMATE  THAT REDUCED  GROSS
          REVENUE. PLEASE ADDRESS THE EFFECT THAT CHANGES IN YOUR ESTIMATES WITH
          RESPECT  TO EACH  ITEM HAD ON YOUR  REVENUES  AND  OPERATIONS  FOR THE
          APPLICABLE PERIODS.

TQC RESPONSE

There have been no  significant  fluctuations  to estimates  when comparing such
items as a relative  percentage  of that years  sales with  respect to each item
that  reduced  gross  revenues in the past except for the results for the fiscal
year ended December 31, 2004, which include a returns provision of approximately
$626,000 in the event of future product returns following the discontinuation of
the Cold-Eeze(R) Cold Remedy Nasal Spray product in September 2004.

2.   WE NOTE THAT YOUR ACCOUNTING POLICY WITH RESPECT TO COMMISSION EXPENSE PAID
     TO  DISTRIBUTORS/BROKERS OF YOUR PRODUCTS VARIES DEPENDING ON THE NATURE OF
     THE UNDERLYING AGREEMENT; THAT IS, YOU CLASSIFY CERTAIN COMMISSIONS PAID AS
     A COST OF SALES  VERSUS  ADMINISTRATIVE  EXPENSE.  PLEASE  PROVIDE US, IN A
     DISCLOSURE-TYPE  FORMAT, MORE ABOUT THE NATURE OF THE UNDERLYING  AGREEMENT
     THAT DETERMINES YOUR COMMISSION CLASSIFICATION. IN ADDITION, PLEASE TELL US
     WHY YOU BELIEVE THAT YOUR  CLASSIFICATIONS ARE APPROPRIATE UNDER U.S. GAAP,
     REFERENCING THE AUTHORITATIVE LITERATURE THAT SUPPORTS YOUR TREATMENT.

TQC RESPONSE

                                       4

The following  discussion and citations of U.S. GAAP use  correlations to relate
meaningful  costs that would be  comparative  to other  industries  and that are
relative to sales or relative to other operating  expenses for the two operating
segments  of TQC that  use  different  methodologies  for the  marketing  of its
products.  FAS89, paragraph 17 states "The current cost of inventory owned by an
enterprise is the CURRENT COST OF PURCHASING THE GOODS  CONCERNED OR THE CURRENT
COST OF THE  RESOURCES  REQUIRED TO PRODUCE THE GOODS  CONCERNED  (including  an
allowance for the current  overhead costs according to the allocation bases used
under generally accepted accounting  principles),  whichever would be applicable
in the circumstance of the enterprise.

ARB43,  paragraph 12-4,  statement 3 states "the primary basis of accounting for
inventories is cost,  which