Mail Stop 3561
								February 14, 2006

Mr. Howard B. Bernick, President
Alberto-Culver Company
2525 Armitage Avenue
Melrose Park, Illinois 60160

Re:	Alberto-Culver Company
Form 10-K for the fiscal year ended September 30, 2005
Filed December 9, 2005
File No. 001-05050

Dear Mr. Bernick:

We have limited our review of your filing to the issue addressed in
our comment below.  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 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 on 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 September 30, 2005

Exhibit 13

Management`s Discussion and Analysis

Reconciliation of Non-GAAP Financial Measures, page 30

1. In future filings please avoid presenting non-GAAP measures on a
per share basis.  Per share data other than that relating to net
income generally is not appropriate.  Please see Question (11) of the
Frequently Asked Questions Regarding the Use of Non-GAAP Financial
Measures available at the SEC.gov.
	Please respond to these comments within 10 business days or tell
us when you will provide us with a response.  Please furnish a letter
with your responses to our comments and provide any requested
supplemental information.  Please understand that we may have
additional comments after reviewing your responses to our comments.
Please file your response letter on EDGAR as a correspondence file.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to be
certain that they have provided all information investors require for
an informed 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.

	If you have any questions regarding this comment, please direct
them to Scott Stringer, Staff Accountant, at (202) 551-3272 or, in his
absence, to the undersigned at (202) 551-3841.  Any other questions
regarding disclosures issues may be directed to H. Christopher Owings,
Assistant Director at (202) 551-3725.

		Sincerely,



		Michael Moran
		Branch Chief


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Mr. Howard B. Bernick, President
Alberto-Culver Co.
February 14, 2006
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