January 31, 2007



Via Facsimile 949-475-4756 and U.S. Mail

James J. Moloney
Gibson Dunn & Crutcher LLP
4 Park Plaza
Irvine, CA 92614-8557

Re:	Parlux Fragrances, Inc.
DEFA14A filed January 29, 2007
SEC File No. 0-15491

Dear Mr. Moloney:

The staff in the Office of Mergers and Acquisitions has the
following
comment on the filing listed above.

1. We note the statement that "Mr. Nussdorf`s family-controlled
Quality King has been the subject of dozens of civil and criminal
matters relating to, among other things, Quality King`s
distribution
of counterfeit goods and infringement of trademarks."  Based on
the
supplemental support provided for such statement, the matters to
which you refer appear to be a minimum of seven years old and
precede
a United States Supreme Court ruling that Quality King had not
violated copyright laws.  Please revise your definitive proxy
statement so that it does not omit appropriate balancing
disclosure.

Closing Comments
Please amend your proxy materials in response to this comment.
You
may wish to provide us with a black-lined copy of the revised
consent
revocation statement to expedite our review.
Furnish a cover letter with your amended filing that keys your
responses to our comments and provides any requested supplemental
information. Please file such letter on EDGAR.  Detailed cover
letters greatly facilitate our review.

Please understand that we may have additional comments after
reviewing your amended filing, responses to our comments and any
additional soliciting materials you may file. If you have any
questions, please do not hesitate to contact me at (202) 551-3345

Sincerely,



Michael Pressman
Special Counsel
Office of Mergers and Acquisitions



James J. Moloney, Esq.
January 31, 2007
Page 2



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0303

         DIVISION OF
CORPORATION FINANCE