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              August
      20, 2009

    Jim B.
Rosenberg

    Senior
Assistant Chief Accountant

    United
States Securities and Exchange Commission

    100 F
Street, N.E.

    Washington,
D.C. 20549

              Re:

              The
      Quigley Corporation

              Form
      10-K for the Fiscal Year Ended December 31,
2008

              Filed
      March 9, 2009

              Definitive
      Proxy Statement on Schedule 14A

              Filed
      April 2, 2009

              File Number:
      000-21617

    Dear Mr.
Rosenberg:

    On behalf
of The Quigley Corporation (the “Company”) we hereby transmit via EDGAR the
following responses to the Staff’s comment letter of July 22,
2009.  We have also attached a letter from the Company including
representations regarding its disclosure.  To assist your review, we
have retyped the text of the Staff’s comments in bold face type.

    Form
10-K for Fiscal Year Ended December 31, 2008

    Item
1.  Business

    Overview, page
10

              1.

              We
      note that your company refers to five specific customers that together
      account for a significant percentage of sales volume.  We
      further note that these top five customers represented 48% of your
      company’s consolidated gross revenue for the 2008 fiscal
      year.  To the extent that you have relationships that exceed 10%
      of revenue with any of these individual customers, please disclose this
      information in your Business section pursuant to item 101(c)(vii) of
      Regulation S-K.

      Response:

              For
      the fiscal years ended December 31, 2008, 2007 and 2006, gross revenues
      from Wal-Mart Stores, Inc., and Walgreen Co., as a percentage of
      consolidated gross revenues, were as
follows:

              Customer
      Name

              Fiscal
      Year 2008

              Fiscal
      Year 2007

              Fiscal
      year 2006

                     Wal-Mart

              13.5%

              14.2%

              12.6%

                     Walgreens

              13.7%

              13.4%

              15.2%

    We will
provide this disclosure in future filings.

      KELLS
BUILDING · 621 N.
Shady Retreat Road ·
PO Box1349 ·
Doylestown, PA 18901-1349 · U.S.A

      Telephone:
215-345-0919 · Fax:
215-345-5920 · For
information: www.quigleyco.com

              2.

              In
      your Business section, we note that you list a total of 33
      U.S.  and foreign patents; and on page 10, you indicate some of
      these patents that have been assigned to the company.  Please
      provide us with the following
disclosure:

              a.

              Identify
      who originated the patents,

              b.

              Who
      assigned the patents to the
company,

              c.

              When
      the patents were assigned to the
company,

              d.

              The
      material terms of any agreements related to the assignment of the patents;
      and please file these agreements as exhibits to your Form
      10-K.

    Additionally,
to the extent that any other intellectual property or know-how were in-licensed
or otherwise acquired, please disclose the material terms of the related
in-licensing or acquisition agreements and file these agreements as exhibits to
your Form 10-K.

      Response:

    The list
of the 33 U.S. and foreign concepts and/or inventions, patent applications and
patents that  are subject to an Agreement (defined below), were
originated by Dr. Rosenbloom, Executive Vice President and Chief Operating
Officer, Quigley Pharma Inc., (“Pharma”), a wholly-owned subsidiary of the
Company prior to the date he became employed by The Quigley
Corporation.

    The 33
U.S. and foreign patents were assigned by Dr. Richard Rosenbloom, to the Company
pursuant to the Agreement on
Assignment and Compensation for Inventions (the
“Agreement”).   The Agreement was executed between Dr. Richard
Rosenbloom and the Company dated July 2, 2008.

    The
Agreement was filed as Exhibit 10.1 to the Company’s Form 10-Q for the quarter
ended June 30, 2009.

    The
Company has no other such agreements.

              3.

              We
      further note that you have referenced in your Business section that you
      procure the raw materials used in the production of your cold-remedy
      products from a single vendor, but you do not disclose the name of this
      vendor or the extent of your company’s production requirements being
      fulfilled by this vendor.  Please disclose this information in
      your Business section pursuant to item 101(c) of Regulation
      S-K.  In addition, please either file the related contracts as
      exhibits to your Form 10-K, or alternatively, provide us with a
      substantive analysis as to why your company is not substantially dependent
      upon the arrangements.

      Response:

              The
      single source vendor referenced in our Annual Report on Form 10-K was our
      wholly-owned subsidiary, Quigley Manufacturing Inc.
      (“QMI”).  Prior to October 2004, QMI was a third party contract
      manufacturer requiring the disclosure of a single source
      supplier.  As a consequence of the Company’s acquisition of QMI
      in October 2004, this disclosure is no longer
  pertinent.

    In
response to the Staff’s comment, we made the following disclosure in the
Company’s Form 10-Q for the quarter ended June 30, 2009 and we will provide
similar disclosure in our future filings.

    The
primary revenue producing product of the Company’s cold remedy segment is the
Cold-EEZEÒ
zinc gluconate glycine lozenge product which is available in various flavors for
purchase by the consumer at retail stores.  The Company also produces
zinc private label lozenge products for sale to retail customers.  Net
sales from zinc lozenge products accounted for 98.9% and 89.9% of the cold
remedy segment net sales for the years ended December 31, 2008 and 2007,
respectively.  These zinc lozenge products are manufactured by Quigley
Manufacturing Inc., the Company’s wholly-owned subsidiary.  The
constituent raw materials and packaging used in the manufacture and presentation
of these items are procured from various sources with additional suppliers
having been identified in the event that alternatives are
required.  While the absence of a current raw materials or packaging
source may cause short term interruption, identified alternative sources would
fill the Company’s needs in a short time and any transition period would be
mitigated by adequate levels of finished product available for
sale.  Other products within the cold remedy segment such as
Cold-EEZEÒ Sugarfree
tablets, Kids-EEZEÒ
Chest Relief and Immune Support Complex 10 are manufactured for the Company by
third party contract manufacturers and while currently purchased from single
sources do not constitute a material revenue risk to the Company if product
availability was jeopardized.

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

    Critical Accounting
Estimates, page 27

              4.

              Please
      revise your disclosure which discusses the terms of your sales return
      policy, including the amount of time after a sale in which the product can
      be returned, for what reasons a return is accepted and the form of the
      return (i.e.  credit issued, cash returned, product exchanged
      out of inventory for returned product).  If you exchange product
      out of inventory, disclose in your notes to financial statements how you
      account for your estimate of these returns at the time of sale of the
      product and how you account for returns at the date they are actually
      returned to you Provide us an analysis supporting your accounting
      treatment with reference to the authoritative literature you rely upon to
      support your accounting.  It also may be helpful to provide us
      an example showing the journal entries
made.

    Response:

    In
response to the Staff’s comment, we made the following disclosure in the
Company’s Form 10-Q for the quarter ended June 30, 2009 and we will provide
similar disclosure in our future filings.

    Critical Accounting
Policies

    The
preparation of financial statements in conformity with generally accepted
accounting principles require management to make estimates and
assumptions.  Those estimates and assumptions affect the reported
amounts of assets and liabilities, disclosure of contingent assets and
liabilities, and the reported revenues and expenses of the
Company.   The Company’s significant accounting policies are
described in Note 2 of Notes to Condensed Consolidated Financial Statements
included under Item 8 of this Part II.     However,
certain accounting policies are deemed “critical”, as they require management’s
highest degree of judgment, estimates and assumptions.  The Company
applies the principles of Statement of Financial Accounting Standard No. 48
“Revenue Recognition When
Right of Return Exists”, relative to accounting for product
returns.  These accounting estimates and disclosures have been
discussed with the Audit Committee of the Company’s Board of
Directors.  A discussion of the Company’s critical accounting
policies, the judgments and uncertainties affecting their application and the
likelihood that materially different amounts would be reported under different
conditions or using different assumptions are as follows:

    Sales Returns and
Allowances

    The
Company is organized into three different but related business segments, cold
remedy, contract manufacturing and ethical pharmaceutical. When providing for
the appropriate sales returns, allowances, cash discounts and cooperative
incentive promotion costs, each segment applies a uniform and consistent method
for making certain assumptions for estimating these provisions that are
applicable to that specific segment. Traditionally, these provisions are not
material to net income in the contract manufacturing segment. The ethical
pharmaceutical segment does not have any revenues.

    The primary product in the cold remedy
segment, Cold-EEZEÒ,
has been clinically proven to reduce the severity and duration of common cold
symptoms. Accordingly, factors considered in estimating the appropriate sales
returns and allowances for this product include it being (i) a unique product
with limited competitors, (ii) competitively priced, (iii) promoted, (iv)
unaffected for remaining shelf-life as there is no product expiration date, and
(v) monitored for inventory levels at major customers and third-party
consumption data.  The Company has recently added new products to the
cold remedy segment such as Kids-EEZEÒ
Chest Relief, ISC-10 immune product and Organix Organic Cough and Sore Throat
Drops.  Each of these new products do carry shelf-life expiration
dates for which the Company aggregates such new product market experience data
and updates its sales returns and allowances estimates accordingly.

    Currently,
the Company does not impose a period of time within which product may be
returned.  All requests for product returns must be submitted to the
Company for pre-approval.  The main components of the Company’s
returns policy are: the Company will accept returns  that are (i) due
to damaged product that is un-saleable and such return request activity fall
within an acceptable range, (ii) for products of the Company that have reached
or exceeded designated expiration dates, (iii) in the event that the Company
discontinues a product, the customer will have the right to return only such
item that it purchased directly from the Company.  The Company will
not accept return requests pertaining to customer inventory “Overstocking” or
“Resets”.   The Company will only accept return requests for
product in its intended package configuration.  The Company reserves
the right to terminate shipment of product to customers who have made
unauthorized deductions contrary to the Company’s Return Policy or pursue other
methods of reimbursement. The Company compensates the customer for authorized
returns by means of a credit applied to amounts owed or to be owed and in the
case of discontinued product only, also by way of an exchange.  The
Company does not have any significant product exchange history.

    Additionally,
as requested, the following forms of journal entries utilized by the Company to
reflect general and specific return transactions generated by actual or
anticipated product return activity are provided supplementally to the
Staff:

              1.
      General provision for

              Dr.
      Returns expense (component of net sales)

              $XXX

              estimated
      future returns:

              Cr.
      Accounts receivable return allowance

              $XXX

              2. Recognizing
      specific

              Dr.
      Accounts receivable return allowance

              $XXX

              return
      transactions

              Cr.
      Customer account receivable

              $XXX

              (where
      a provision has been booked)

              Recognizing
      specific

              Dr.
      Returns expense (component of net sales)

              $XXX

              return
      transactions

              Cr.
      Customer account receivable

              $XXX

              (where
      a provision has NOT been booked)

              5.

              You
      have explained the increase in the return amount for the past two years as
      non-routine.  Disclose why you believe the increase is
      non-routine and not a developing
trend.

    Response:

    In
response to the Staff comments, the following revised disclosure was
incorporated into the recent filing of the Company’s Form 10-Q for the quarter
ended June 30, 2009 and will be incorporated into future filings:

    The
increase in the 2008 return amount was principally due to non-routine returns of
obsolete product and product mix realignment by certain of our
customers.  This increase was largely related to returns or return
reserves for new products of the Company which carry a shelf-life expiration
date, whereas the Cold-EEZEÒ
lozenge product does not have an expiry date and historically the lozenge
product had been the primary constituent of cold remedy sales prior to the
launch of the products that carry expiry dates.  While these factors
resulted in higher returns to the Company in 2008 compared to previous years,
future returns provisions will accommodate these changing components in
evaluating product return reserves along with recognizing evolving changes in
the complexion of the Company’s cold remedy products, particularly with the
addition of products with expiry dates.

    Results of
Operations

    Year ended December 31, 2008
compared with same period 2007, page 28

              6.

              Please
      revise your disclosure to explain your large increase in obsolete
      inventory during 2008 of approximately $830,000.  Please state
      which product(s) were considered obsolete and the expected effects on
      future financial position and results of operations of the product(s)
      going obsolete.

    Response:

    In
response to Staff comments, the following provides additional information on a
particular set of facts specific to circumstances existing at December 31, 2008
and 2007:

    Product
obsolescence provisions increased by approximately $830,000 at December 31, 2008
as compared to December 31, 2007.  This increase was principally due
to (i) a charge of $510,000 for the ISC-10 product as a consequence of pending
product expiration dates and (ii) a charge of $200,000 for inventory impairment
in connection with QMI’s Elizabethtown facility planned closure in
2009.

    No
s