Mail Stop 3561

      							March 16, 2006


Mr. Laurence Sellyn
Executive Vice President, Chief Financial and Administrative
Officer
Gildan Activewear Inc.
725 Montee de Liesse
Montreal, Quebec, Canada  H4T 1P5

	Re:	Gildan Activewear Inc.
      Form 40-F for Fiscal Year Ended October 2, 2005
		Filed December 23, 2005

Dear Mr. Sellyn:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your documents 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 or may not
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 40-F for Fiscal Year Ended October 2, 2005

Exhibit 99.1

Selected Annual Information, page 23

1. Revise to present selected financial information for the last 5
fiscal years, with corresponding amounts in US GAAP, if different.

Operating Results 2004-2005, page 24

2. We note that you identify a number of factors that affected the
increase in net sales and changes in cost of sales and SG&A.
Revise
your discussion to quantify the impact of each factor.  Also
discuss
whether you expect trends to continue or change and the reasons
why.
Refer to Item 303 of Regulation S-K.

3. Please disclose the types of expenses that you include in the
cost
of sales line item and the types of expenses that you include in
the
selling, general and administrative expenses line item.  In doing
so,
please disclose specifically:

* Whether you include inbound freight charges, purchasing and
receiving costs, inspection costs, warehousing costs, internal
transfer costs, and other costs of your distribution network in
cost
of sales.  If you currently exclude a portion of these costs from
cost of sales, please tell us why and disclose:

* In a footnote the line items that these excluded costs are
included
in and the amounts included in each line item for each period
presented, and
* In your MD&A that your gross margins may not be comparable to
others, since some entities include the costs related to their
distribution network in cost of sales and others like you exclude
all
or a portion of them from gross margin, including them in a line
item
such as selling, general and administrative expenses.

Disclosure Controls, page 39

4. We note your disclosure that you evaluated your disclosure
controls and procedures as defined by Rule 13a-15(e) and that you
concluded your controls and procedures were effective in ensuring
the
officers would be advised of material information about the
registrant from others.  Please revise to clarify if the
information
communicated to your management is done so to allow timely
decisions
regarding required disclosure.  Further, please address, if true,
that these controls are effective to give reasonable assurance
that
the information required to be disclosed by the Company in reports
that it files under the Exchange Act is recorded, processed,
summarized and reported within the time periods specified in the
rules and forms of the SEC.  See Exchange Act Rule 13a-15(e).

Exhibit 99.2

Consolidated Statements of Earnings, page 50

5. In future filings, please ensure that all costs of a similar
nature are included in the same financial statement caption for
comparative purposes.  As an example, we note that you recorded
losses for asset write downs in 2004 as a component of selling,
general and administrative expenses, while similar charges in 2005
were recorded as a special charge.

Note 14 Other Information, page 65

6. We note that you closed two of your Canadian yarn-spinning
operations in 2004.  Please confirm for us that the writedown
recorded relates solely to the assets that were NOT transferred to
the joint venture.  With regard to the assets that were
transferred
to the joint venture, please provide us with more details
regarding
this transfer and revise your disclosure accordingly.  For
example:
* When you transferred the assets to the joint venture, did the
venture recognize a gain or loss on the transfer?
* Did the joint venture partner also transfer assets of equivalent
value to the venture?
* If not, did your ownership percentage in the joint venture
change?

Exhibit 99.4

7. Please confirm that the inclusion of the titles of your Chief
Executive Officer and Chief Financial Officer was not intended to
limit the capacity in which such individuals provided the
certifications.  In the future, eliminate reference to the titles
in
the introductory paragraph of the certifications to conform to the
format provided in Item 601(b) (31) of Regulation S-K.

*    *    *    *

      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
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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Kathleen Kerrigan, Staff Accountant, at
(202)
551-3369 or Donna Di Silvio, Senior Staff Accountant, at (202)
551-
3202 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3841with any other questions.

								Sincerely,



								Michael Moran
						Accounting Branch Chief



Mr. Laurence Sellyn
Gildan Activewear Inc.
March 16, 2006
Page 4