Mail Stop 3561
								March 28, 2006
Tracey T. Travis
Senior Vice President and
Chief Financial Officer
Polo Ralph Lauren Corporation
650 Madison Avenue
New York, NY  10022


      Re:	Polo Ralph Lauren Corporation
		Form 10-K for the Fiscal Year Ended April 2, 2005
		Form 10-Q for the Quarterly Period Ended December 31,
2005
		File No. 1-13057


Dear Ms. Travis

      We have reviewed your filings and have the following
comments.
We have limited our review of your filings to those issues we have
addressed in our comments.  Please provide a written response to
our
comments.  Please be as detailed as necessary in your
explanations.
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.


Form 10-K for the Fiscal Year Ended April 2, 2005

Notes to Consolidated Financial Statements, page F-10

Note 1.  Significant Accounting Policies, page F-10

Revenue Recognition, page F-11

1.	Please tell us when you recognize revenues from products
ordered
through your web-site.  If web-site orders and/or wholesale orders
are shipped using FOB destination terms, tell us whether you
estimate
delivery dates and the significant assumptions you use to do so.
If
applicable, please also tell us how you assess the accuracy of
your
estimates given the variability among carriers, methods of transit
and on-time performance.  In addition, please tell us the amount
of
deferred revenue, and balance sheet classification, at each
balance
sheet date.

2. We note per review of your web site that you sell gift cards.
Please tell us the amount of gift cards you sold in fiscal 2005
and
2004.  Please also tell us your accounting policies related to
gift
cards, including those related to recognition of revenue and
breakage.

Advertising, page F-14

3. Please explain to us why you believe that consideration paid to
customers under your cooperative advertising programs is
appropriately characterized as SG&A expense based on the
conditions
in Issue 1 of EITF 01-9.  In doing so, please tell us:

* The terms and conditions of your cooperative advertising
programs,
the related terms and conditions contained in customer agreements
and
the nature and extent of documentation you require from customers
to
qualify for the allowances;

* Why you believe the advertising benefits you receive is
sufficiently separable from purchases of your products;

* How you determine the fair value of the advertising benefits you
receive; and

* How you determine that the consideration paid does not exceed
the
fair value of the advertising benefits received.



Note 4.  Acquisitions and Joint Venture, page F-20

4. Please tell us the methodology you used to determine the fair
value of the intangible assets you identified and recognized upon
your purchase of RL Childrenswear Company.  Please also tell us
how
you treated the license agreement and order backlog of RL
Childrenswear in your determination of intangible assets that
should
be recognized apart from goodwill.  Finally, please tell us the
primary reasons for the acquisition of RL Childrenswear and the
factors that contributed to a purchase price that resulted in
recognition of goodwill.

5. In future filings, please disclose earnings or losses of equity
method investees and minority interests in the net income or loss
of
subsidiaries separately on the face of your statements of
operations.
Please also disclose minority interests separately on the face of
your balance sheets.

Form 10-Q for the Quarterly Period Ended December 31, 2005

Notes to Consolidated Financial Statements, page 6

Note 5.  Acquisitions, page 12

6. We note that you settled all claims under your litigation with
Jones as part of your acquisition of the Polo Jeans business.
Please
tell us the methodology you used to measure the fair value of the
settlement.  Please also tell us how you determined the fair value
of
the footwear license in connection with your acquisition of Ralph
Lauren Footwear Co., Inc. and whether you recognized a settlement
gain or loss upon the reacquisiton of the license.  In future
filings, please disclose the valuation method you use to determine
the settlement amount of preexisting relationships with acquired
entities.  Please refer to EITF 04-1, Accounting for Preexisting
Relationships between the Parties to a Business Combination.

* * * * *

       Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your 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
Exchange 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 our review of your filing or in
response to our comments on your filing.

	You may contact Scott Ruggiero at (202) 551-3331 or William
Thompson at (202) 551-3344 if you have questions regarding
comments
on the financial statements and related matters.  Please contact
me
at (202) 551-3716 with any other questions.


Sincerely,


William Choi
Branch Chief


Ms. Tracey Travis
Polo Ralph Lauren Corporation
March 28, 2006
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