SecProbe.io

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Mail Stop 3561

      							 July 11, 2005

By Facsimile and U.S. Mail

Mr. George Horowitz
Chairman and CEO
Everlast Worldwide, Inc.
1350 Broadway, Suite 2300
New York, NY 10018

      Re:    	Everlast Worldwide, Inc.
      	Form 10-K for the Fiscal Year Ended
      	December 31, 2004
      	Filed on March 28, 2005
                	File No.  0-25918

Dear Mr. Horowitz:

	We have reviewed your response dated June 20, 2005 to our
comment letter dated June 1, 2005 and have the following
additional
comments.   Please understand that the purpose of our review 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.  Feel free
to
call us at the telephone numbers listed at the end of this letter.

Independent Registered Auditor`s Report, page 1-F

1. We note your response to comment 6 in our letter dated June 1,
2005.  Please clarify your reference to our records in your
response.
As of June 22, 2005, the Public Company Accounting Oversight Board
("PCAOB") has Berenson and Company LLP as a registered independent
accounting firm.  It does not list Berenson LLP as a registered
public accounting firm or state there is a pending application for
this entity.  Please tell us why you believe your independent
accountant is registered with the PCAOB and why your auditor`s
report
is compliant with Rule 2-01(f)(1) of Regulation S-X.

Consolidated Balance Sheets, page 2-f

2. We note your response to comment 7 in our letter dated June 1,
2005.  In future filings please provide a reconciliation of your
accounts receivables assigned to factor, advances from factor,
amount
due from (to) factor, unfactored accounts receivable subtotal,
allowanced for doubtful accounts and net accounts receivable as of
your balance sheet dates.  In your response, please show us what
your
revised disclosure will look like.

3. We further note that you record the assigned accounts
receivable
as a sale and also believe the entire factor transaction can be
viewed as a financing transaction.  In this regard, cash inflows
from
the transfer of receivables arising from the sale of goods or
services that qualify for sale accounting are generally classified
as
operating cash inflows.  Reference is made to paragraph 22(a) of
FAS
95.  Please clarify and advise us of the accounting basis
supporting
your net reporting or revise.

Notes to Consolidated Financial Statements, page 7-f

4. We note your response to comment 10 in our letter dated June 1,
2005.  It is not evident that performance of the company is not
assessed based on different components of the company and that
financial information about these components is not available.
Please
identify which person or personnel are responsible for directly
allocating resources to and assessing the performance of your
apparel, sporting goods and/or licensing activities and provide us
with a copy of all existing reports which summarize and present
your
business activities to your chief operating decision maker(s). We
may
have further comment.

Restructuring and non-recurring charges, page 13-f

5. We note your response to comment 14 in our letter dated June 1,
2005.  Please clarify your reference to EITF No. 96-9 which
discusses
the required statement of operations classification for inventory
markdowns.  Costs associated with a restructuring activity that do
not meet the conditions in paragraph 2 of SFAS No. 146 are
incremental period costs and shall not be recognized before they
are
incurred.   See paragraph 17 of SFAS No. 146.  Please advise or
revise to reflect $1 million of non-recurring idle capacity and
product continuation costs in the periods they are incurred.  In
your
response, please show us what your revised disclosure will look
like.

	Please send us your response to our comment within 10
business
days from the date of this letter or tell us when you will provide
us
with a response.  Please understand that we may have additional
comments after reviewing your response to our comment.  Your
supplemental response letter should be submitted in electronic
form
on EDGAR as a correspondence file.  Refer to Rule 101(a) of
Regulation S-T.

		If you have any questions regarding our comments, please
direct them to Brian V. McAllister at (202) 551-3341 or, Donna Di
Silvio at (202) 551-3202, or in her absence to the undersigned at
(202) 551-3841.

									Sincerely,

									Michael Moran
									Accounting Branch
Chief
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Mr. George Horowitz
Everlast Worldwide, Inc.
July 11, 2005
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