Mail Stop 3561
								February 17, 2006

Mr. Bryan L. Timm
Vice President and Chief Executive Officer
Columbia Sportswear Company
14375 Northwest Science Park Drive
Portland, Oregon 97229

	RE:	Columbia Sportswear Company
		Form 10-K for the Fiscal Year Ended December 31, 2004
		Filed March 9, 2005
		File No. 0-23939

Dear Mr. Timm:

	We have reviewed the responses in your letter filed on
January
31, 2006 and have the following additional comments.  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 Year Ended December 31, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 15

1. We have reviewed your response to prior comment 1.  We advise
you
that the inclusion of the proposed reconciliation does not have
the
effect of making your non-GAAP measure a financial measure
calculated
and presented in accordance with GAAP.  Please expand your
disclosure
to indicate the reasons why you believe presentation of this non-
GAAP
measure provides useful information to investors and how
management
uses this non-GAAP measure in evaluating operating performance.
Refer to Release 33-9176.
Results of Operations, page 16

Year Ended December 31, 2004 Compared to Year Ended December 31,
2003

2. We have reviewed your response to prior comment 5 and would
like
you to further expand your explanations to describe the underlying
factors that attributed to your net sales increases.  We note your
enhanced explanations for the increases in outerwear and footwear
were primarily a result of increased sales to large-account
customers; however, you did not describe why sales to large-
account
customers increased and how you achieved those increases.
Additionally, please revise or further explain what is meant by
"improvement in the segmentation of our products for specific
distribution channels and targeted customers" when describing your
reasons for increased sportswear sales.  You may want to describe
the
specific improvements that were made for each distribution channel
and explain how those improvements increased sales of sportswear.


*      *      *      *      *

      As appropriate, 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 response 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 response to our comments.

		You may contact Yong Kim at (202) 551-3323 if you have
any
questions regarding these comments.  Please contact me at (202)
551-
3716 with any other questions.


							Sincerely,



							William Choi
							Branch Chief


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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

        	DIVISION OF
	    CORPORATION FINANCE





Mr. Bryan L. Timm
Columbia Sportswear Company
February 17, 2006
Page 2