SecProbe.io

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<FILENAME>filename1.txt
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Mail Stop 3561
November 16, 2005
Patrick W. Hurley
Chief Financial Officer
Sport-Haley, Inc.
4600 East 48th Avenue
Denver, CO  80216-3215

      Re:	Sport-Haley, Inc.
		Form 10-K for the Fiscal Year Ended June 30, 2005
      Filed October 13, 2005
		File No. 033-74876-D

Dear Mr. Hurley:

      We have limited our review of your filing to those issues we
have addressed in our comments.  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 our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
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.

Facing Page
1. We note you indicate here that your common stock is a class of
securities registered under Section 12(g) of the Exchange Act.  A
review of your Edgar filing history, however, appears to reflect
only
one Exchange Act registration statement:  a Form 8-A filed March
8,
1994 registering your common stock under Section 12(b).  Please
tell
us when and how you registered your common stock under Section
12(g).

Market for Registrant`s Common Equity and Related Shareholder
Matters, page 11
2. The Item 201(b)(1) of Regulation S-K disclosure here indicates
your "estimate that there were approximately 900 holders of record
of
your common stock" although "the vast majority of [y]our shares
are
held in `street name,` and the actual number of holders may differ
from [y]our estimate."  By contrast, in your Forms 10-K for the
2001
through 2004 fiscal years, you disclosed only that your shares
were
held by approximately between 900-1000 shareholders, without any
reference to whether the figure represented record holders.  In
your
Forms 10-K for the 2000 and prior fiscal years, however, you did
disclose having fewer than 100 holders of record.  Please confirm
to
us this 2005 Form 10-K disclosure of approximately 900 holders
does
represent record holders.  Please also tell us whether the 2001
through 2004 Forms 10-K disclosure represented record holders, and
if
not, what the actual number of record holders of your common stock
was as of the latest practicable date for the fiscal years 2001
through 2004.
****
      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with your filing.

	If you have any questions, please call Lisa Beth Lentini,
Attorney-Advisor, at (202) 551-3334, David Mittelman, Branch
Chief,
at (202) 551-3214, or me at (202) 551-3725.

								Sincerely,

								H. Christopher Owings
								Assistant Director
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Patrick W. Hurley
Sport-Haley, Inc.
November 16, 2005
Page 1

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