SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 3561

      							 August 1, 2005

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 July 21, 2005 to our
comment letter dated July 11, 2005 and have the following
additional
comment.   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.

Notes to Consolidated Financial Statements, page 7-f

1. We note your responses to comment 4 in our letter dated June 1,
2005 and comment 10 in our letter dated June 20, 2005.  Your
responses do not sufficiently address the existence or absence of
operating segments or components of an enterprise.  Your reference
to
an inability to allocate operating expenses in your response
letter
dated July 21, 2005 does not preclude you from disclosing the
required segment financial and descriptive information.  SFAS No.
131
requires you to make judgments and allocate amounts of profit or
loss
or assets to operating segments on a `reasonable basis` and
provide a
reconciliation of operating segments to consolidated balances and
explanations of your allocations.  Strong indicators of the
existence
of operating segments may include, but are not limited to, the
following:
* Components of the enterprise engage in business activities which
earn revenues and incurs expenses;
* The components operating results are regularly viewed by the
chief
operating decision maker;
* The manner the company is organized to make key operating
decisions
and to assess performance.  Operating segments usually have
segment
managers directly responsible for maintaining direct communication
with the chief operating decision maker to discuss operating
activities, financial results, forecasts, or plans for the
segments;
and
* The entity has discrete financial information available for the
operating segments.

Please tell us why you repeatedly refer to apparel, sporting goods
and licensing activities in your response letters dated June 20
and
July 21, 2005 and Form 10-K.  Include an explanation why you do or
do
not believe the entity has operating segments that specifically
addresses all of the criteria in paragraphs 10 - 15 of SFAS No.
131.
Include in your response an organizational hierarchy chart for the
company, an explanation of the functions or areas the company
segregates within its management structure and all existing
internal
reports for which discrete financial information is available.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
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.

		You may contact Brian V. McAllister at (202) 551-3341
or,
Donna Di Silvio at (202) 551-3202 regarding comments on the
financial
statements and related matters.

									Sincerely,

									Michael Moran
									Accounting Branch
Chief
??

??

??

??

Mr. George Horowitz
Everlast Worldwide, Inc.
August 1, 2005
Page 1

</TEXT>
</DOCUMENT>