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June 7, 2005

VIA
EDGAR AND FEDERAL EXPRESS

United States Securities and Exchange Commission

450 Fifth Street, N.W., Mail Stop 03-08

Washington, D.C. 20549

Attention:  George F. Ohsiek, Jr.

Re:          Haggar Corp. [File No. 0-20850]

Form 10-K for the Fiscal Year Ended September 30, 2004

Filed December 10, 2004

Form 10-Q for the Quarter Ended December 31, 2004

Filed February 9, 2005

Dear Mr. Ohsiek:

Haggar Corp. (the “Company”) respectfully submits the following
responses to the comments of the staff (the “Staff”) of the Securities and
Exchange Commission set forth in a comment letter dated May 25, 2005 (the “Comment
Letter”).  For your convenience, we have
repeated in bold print each comment of the Staff exactly as it appears in the
Comment Letter and provided our response below each comment.

Form 10-K for
the Fiscal Year Ended September 30, 2004

1.                                      We have reviewed your response to comment 6 in our letter dated April 18,
2005 and note your proposed disclosure that “[t]he Company records its best
estimate of margin allowances, returns, co-operative advertising and rebates at
the later of the date at which the related revenue is recognized or the date at
which the allowance is offered to the customer.”  We are unclear as to why returns are
recognized at the later of the date at which the related revenue is recognized
or the date at which the allowance is offered.    Please clarify the disclosure
accordingly.  Please also revise the disclosure
to clarify the circumstances under which margin allowances, cooperative
advertising allowances, and rebates are offered to customers at dates other
than the time of sale and revenue recognition.
Show us how the revised disclosure will read.

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Response:

In response to your comment, we have modified
our revenue recognition policy disclosure to clarify the timing of recording an
allowance for estimated returns and the circumstances under which margin
allowances, cooperative advertising allowances and rebates are offered to customers
at dates other than the time of sale and revenue recognition.  The revised disclosure is stated in Exhibit A.

 Form 10-Q for the Quarter Ended December 31,
2004

Item 4.  Controls and Procedures, page 21

2.                                      We have reviewed your response to comment 14 in our letter dated April 18,
2005.  Please provide footnote disclosure
in your next filing on Form 10-Q regarding the error corrections you
recorded in the fiscal quarter ended December 31, 2004.  The disclosure should indicate the nature of
each of the errors you identified, how and when you discovered the errors, the
individual and net impact of the errors on your historical, and the individual
and net impact of correcting the errors on the year to date results of
operations.  Refer to paragraph 37 of APB
20.  The disclosure should also indicate
that management has not restated the historical results because it believes the
errors to be quantitatively and qualitatively immaterial on an individual and
net basis.  Please show us how the
disclosures will read.

Response:

We will disclose in the notes to the
consolidated financial statements of the Form 10Q for the quarter ended June 30,
2005, our disclosure on the error corrections the Company recorded in the
fiscal quarter ended December 31, 2004.
The disclosure is stated in Exhibit B.

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In submitting these responses, we acknowledge
the following:

•                  The Company
is responsible for the adequacy and accuracy of the disclosures in its filings.

•                  Any Staff comments
or changes to disclosures in response to Staff comments do not foreclose the
Commission from taking any action with respect to our filings.

•                  The Company
may not assert Staff comments as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United
States.

If you
have any questions regarding the responses above, please direct them to me at
(214) 956-4325.

  Respectfully submitted,

  /s/ John W. Feray

  John W. Feray

  Chief Accounting Officer

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  Exhibit A

Revenue Recognition

Revenue from the sale of products is
recognized upon the transfer of title and risk of ownership to customers.  Revenue from sales at the Company’s retail
stores is recognized when goods are sold to customers.  The Company also negotiates various
allowances with retailers, including margin allowances, returns, rebates,
co-operative advertising, and slotting allowances.  The Company accounts for these types of
customer allowances as follows:

Margin
Allowances

The Company has historically provided allowances to
its customers to assist in meeting margin expectations and to maintain or
establish long-term customer relationships. To determine the adequacy of margin
allowance reserves, as reflected on the financial statements, the Company
periodically reviews potential customer obligations for all product shipped
through the date of the financial statements. These amounts are evaluated
customer-by-customer based on the Company’s historical experience of product
sell-through and retailer performance, current market conditions, the strategic
importance of the customer’s ongoing business relationship and any past
deductions taken by the customer. Settlements of customer allowance
arrangements are periodically compared to the Company’s original estimates to
enhance the Company’s ability to predict customer support levels in subsequent
seasons. Margin allowance arrangements are recorded as a deduction to net sales
generally at the date at which the related revenue is recognized. However,
changes to the Company’s best estimate or new margin allowance arrangements may
occur after the date at which the related revenue is recognized based on
product performance at the retail level for the Company’s customers and other
factors.  These arrangements are recorded
as a deduction to net sales in the period the estimate is revised or the new
margin allowance arrangement.

Returns Allowances

The Company records an
allowance for estimated returns, based on historical experience, as a deduction
to net sales on the date the related revenue is recognized.

Rebate Allowances

Rebates are upfront agreements offered to customers
based on the purchase of specified quantities of products at specified prices.  Rebate allowances are recognized as a
deduction to net sales on the date the
related revenue is recognized.

Co-operative
Advertising Allowances

Support for customers’ advertising activities, product
presentation or other promotions are considered deductions to net sales unless
such support relates to advertising material the Company could obtain
independently, which is recorded as advertising expense, provided the expense
does not exceed the fair value of such services.  The co-operative advertising allowances are
recorded to either net sales or advertising expense on the date the related
revenue is recognized.

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Slotting Allowances

Slotting allowances are negotiated agreements with
customers to obtain space for the Company’s products on customers’ store
shelves.  Slotting allowances are
recognized as a deduction to net sales.
The Company recognizes slotting allowances in the period in which such
allowances are offered to customers.

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  Exhibit B

In connection with the financial statement
close process for December 31, 2004, the Company’s management identified
two accounting errors related to prior reporting periods.  The first error was an understatement of
inventory at September 30, 2004, resulting from utilization of incorrect
finished goods inventory overhead factors at such date.  This error was corrected in the quarter ended
December 31, 2004 and resulted in an overstatement of cost of sales of $760,000
for the quarter ended December 31, 2004.
The second error was an understatement of the customer allowances
reserve at September 30, 2004.  This
error was also corrected in the quarter ended December 31, 2004, and it
resulted in an overstatement of net sales of $773,000 for the quarter ended December 31,
2004.  Management believes that the
impact of these errors was not quantitatively or qualitatively material on an
individual and net basis to the prior period or the quarter ended December 31,
2004.  Therefore, prior period results
have not been restated and the errors corrections were recorded in the quarter
ended December 31, 2004.

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