Mail Stop 3561


								August 29, 2006

Mr. George Feldenkreis
Chief Executive Officer
Perry Ellis International, Inc.
3000 N.W. 107 Avenue
Miami, Florida  33172

		RE:	Perry Ellis International, Inc.
			Form 10-K for Fiscal Year Ended January 31, 2006
			Form 10-Q for Fiscal Quarter Ended April 30, 2006
			File No. 0-21764

Dear Mr. Feldenkreis:

		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.  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 comments
are inapplicable or revisions are 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 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 for the Fiscal Year Ended January 31, 2006

Selected Financial Data, page 21

1. Since you state that you believe that EBITDA provides some
indication of your ability to satisfy your debt obligations, it
appears that you consider it to be a liquidity measure.  In light
of
this, please reconcile EBITDA to net cash provided by operating
activities rather than net income in future filings.  If you
believe
that a reconciliation of EBITDA to net income is also required,
please provide the reconciliation to net cash provided by
operating
activities in addition to the reconciliation to net income.
Please
refer to Item 10(e)(1)(i) of Regulation S-K and Question 12 in
"Frequently Asked Questions Regarding the Use of Non-GAAP
Financial
Measures," issued June 13, 2003 and available on our website at
www.sec.gov.  Reconciliations of EBITDA to net cash provided by
operating activities should also be included in press releases
containing a non-GAAP liquidity measure and furnished pursuant to
Item 2.02 of Form 8-K.  Please refer to Regulation G.

Exhibits 31.1 and 31.2

2. In future filings, please eliminate reference to the titles of
your principal executive and principal financial officers in the
introductory paragraph of the certifications to conform to the
format
provided in Item 601(b)(31) of Regulation S-K.  Their titles
should
only appear after their names and signatures at the bottom of the
certifications.  Please confirm to us 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.

Form 10-Q for the Quarterly Period Ended April 30, 2006

Controls and Procedures, page 23

3. We note that your Chief Executive Officer and your Chief
Financial
Officer concluded that your disclosure controls and procedures
have
been designed and are being operated in a manner that provides
reasonable assurance that the information required to be disclosed
by
you in reports filed under the Securities Exchange Act of 1934, as
amended, is recorded, processed, summarized and reported  within
the
time periods specified in the SEC`s rules and forms and is
accumulated and communicated to your management, including the
Chief
Executive Officer and the Chief Financial Officer, as appropriate
to
allow timely decisions regarding required disclosure.  Please
revise
to disclose the conclusions of your principal executive and
principal
financial officers regarding the effectiveness of your disclosure
controls and procedures as of the end of the period covered by the
report.

Exhibits 31.1 and 31.2

4. Paragraph 4(d) refers to the most recent fourth quarter as
opposed
to the most recent fiscal quarter.  Please revise to use the exact
wording specified in Item 601(b)(31) of Regulation S-K.

		As appropriate, please amend your filings and respond to
these comments within 10 business days, or tell us when you will
provide us with a response.  Please furnish a cover 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 Sondra Snyder at (202) 551-3332, or in
her
absence, William Thompson at (202) 551-3344 if you have questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 551-3849 with any other questions.

							Sincerely,



							James A. Allegretto
							Senior Assistant Chief
Accountant

Mr. George Feldenkreis
Perry Ellis International, Inc.
August 29, 2006
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