SecProbe.io

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                          STANDARD MOTOR PRODUCTS, INC.
                            37-18 Northern Boulevard
                        Long Island City, New York 11101

                                 August 30, 2005

VIA EDGAR

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street N.W.
Washington, DC 20549

Attention:        Martin F. James, Senior Assistant Chief Accountant
                  Praveen Kartholy, Staff Accountant

                  RE:      STANDARD MOTOR PRODUCTS, INC.
                           ANNUAL REPORT ON FORM 10-K FOR THE YEAR ENDED
                           DECEMBER 31, 2004 FILED ON MARCH 31, 2005;
                           FILE NO. 001-04743

Dear Sirs:

                  On behalf of Standard Motor Products, Inc. (the "Company"), we
are responding to the comments of the staff (the "Staff") of the Securities and
Exchange Commission (the "Commission") contained in a letter dated August 16,
2005 in connection with the above-referenced Annual Report on Form 10-K (the
"Form 10-K"). The following responses are numbered to correspond to the Staff's
numbered comments contained in the Staff's letter.

     1.  REPORTS OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

         In connection with the filing of our Form 10-K, our independent
         registered public accounting firm, Grant Thornton LLP ("Grant
         Thornton"), provided us with a "disclaimer" opinion, in which Grant
         Thornton stated that, as of December 31, 2004, it was unable to apply
         procedures to satisfy itself as to the effectiveness of the Company's
         internal control over financial reporting and that the scope of its
         work was not sufficient to enable it to express an opinion of the
         Company's internal control over financial reporting. Given early
         difficulties in implementing Section 404 of the Sarbanes-Oxley Act
         ("SOX 404") as well as a change of auditors in the middle of the year,
         we were unable to complete our SOX 404 documentation, testing and
         assessment for 2004. As such, it was not possible for Grant Thornton to
         conduct the necessary review to opine on our implementation of SOX 404.

         The procedures, which Grant Thornton was unable to perform, related
         primarily to inadequate documentation and incomplete testing of our key
         controls and processes of our IT function. Such procedures,
         particularly for IT, require a significant portion of the review to be
         done in real time. Accordingly, as of December 31, 2004, Grant Thornton
         could not conduct in real time an audit and test of our IT-related

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         processes and key controls because the documentation and testing
         results for such processes and key controls were incomplete on such
         date, and thereby Grant Thornton could not provide us with an opinion
         as to our internal control over financial reporting at the time we
         filed our Form 10-K. Furthermore, for the same reasons as stated above,
         Grant Thornton is currently unable to provide us with an opinion as to
         our internal control over financial reporting because it is unable to
         conduct real time testing of the IT-related key controls and processes
         which we had in place as of December 31, 2004.

         Due to the reasons discussed above, we respectfully advise the Staff
         that we are unable to file an amended Form 10-K to include an opinion
         of Grant Thornton as to the effectiveness of our internal control over
         financial reporting. We advise the Staff that we have since secured the
         necessary resources, both internally and with outside expert
         consultants, and are diligently working to remediate our material
         weaknesses in our internal control over financial reporting. We intend
         to have all appropriate documentation, key controls and procedures in
         place so that Grant Thornton can conduct its audit and testing of our
         key controls and processes as of December 31, 2005. We respectfully
         request that the Staff allow us to obtain an opinion of Grant Thornton
         regarding the effectiveness of our internal control over financial
         reporting for our Annual Report on Form 10-K for the year ended
         December 31, 2005.

     2.  CUMULATIVE EFFECT OF CHANGE IN ACCOUNTING FOR NEW CUSTOMER ACQUISITION
         COSTS

         We supplementally advise the Staff that we relied upon FTB 90-1 to
         support our previous position of capitalizing costs relating to
         acquiring a customer as these costs were directly related to the
         acquisition of new customers and would not have been incurred but for
         the acquisition of such customers. We also believed that since the
         agreements are contractual in nature, it is probable they will result
         in future sales. We believed that this supported our position that
         these costs are incurred to acquire new customers (to be recovered from
         future sales to them) and are not incurred as a result of a single
         exchange transaction.

         In addition, we capitalized only direct costs incurred to acquire the
         new customer and did not capitalize any payroll or fringe benefits as
         these were not considered material. We relied upon FAS 91 to support
         this capitalization policy.

         The Company amortized the deferred new customer acquisition costs over
         12 months for the following reasons:

            o     The Company has long term relationships with almost all of its
                  customers.
            o     Its customers are unlikely to change vendors within one year
                  as much is involved when this change occurs, including various
                  costs and a lot of time negotiating with new vendors. Although
                  the costs noted above are often partially absorbed by the new
                  vendor, the time, effort, disruption to business and amount of
                  cost incurred by the customer is too significant to warrant
                  such changes.

                                      -2-
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            o     Although the stock lifting is incurred in connection with the
                  initial exclusivity arrangement, the Company's performance
                  over time will be a significant factor in maintaining the
                  relationship beyond an initial period. Amortization over one
                  year corresponds to an initial relationship period that
                  benefits from the stock lifting.

         We also relied upon PPL 01-029 ASSISTANCE IN INTERPRETING AND
         IMPLEMENTING STAFF ACCOUNTING BULLETIN (SAB) NO 101 REVENUE RECOGNITION
         IN FINANCIAL STATEMENTS for further support of our deferral of direct
         customer acquisition costs and amortization of such costs over a
         12-month period. Additionally, FTB 90-1 and FAS 60 require new customer
         acquisition costs to be amortized over the expected benefit period, not
         the life of the contract (taking into consideration that most insurance
         contracts can be terminated prior to the contract period). Thus, we
         believed that these two accounting literatures supported the Company's
         policy to amortize the deferred new customer acquisition costs over
         12-month period.

         For all of the reasons set forth above, the Company believed that one
         year was a conservatively representative amortization period.

     3.  REVENUE RECOGNITION

         a)    DISCOUNTS, ALLOWANCES AND INCENTIVES: In connection with our
               sales activities, we offer a variety of customer discounts,
               allowances and incentives, which we believe are common practices
               in our industry. First, we offer cash discounts for paying
               invoices in accordance with the specified discounted terms of the
               invoice. Historical experience is analyzed on a timely basis and
               is applied as a basis for reduction of sales. Second, we offer
               pricing discounts based on volume and different product lines
               purchased from us. These discounts are principally in the form of
               "off-invoice" discounts and are immediately deducted from sales
               at the time of sale. For those customers that choose to receive a
               payment on a quarterly basis instead of "off-invoice", we accrue
               for such payments as the related sales are made and reduce sales
               accordingly. Finally, rebates and discounts are provided to
               customers as advertising and sales force allowances. We account
               for these as a reduction to revenues, based on estimates of the
               criteria that give rise to such allowances, and record them when
               sales are recorded. We routinely review these criteria and our
               estimating process and make adjustments as facts and
               circumstances change. We advise the Staff that we will provide
               further disclosure in our future periodic filings regarding the
               above.

         b)    STANDARD PLUS CLUB: The amounts received for the services
               provided within our Standard Plus Club program are not material
               to our operations. In addition, the services are not offered as
               part of our normal sales as they are not provided to our
               customers. Rather, they are offered to the installers of our
               products as part of our marketing strategy for generating
               increased demand. The expenses incurred in conducting this
               marketing program are only partially offset by the amounts
               charged to the program participants.

                                      -3-
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               Since the services provided by the Standard Plus Club are not
               provided to our customers in addition to our product sales to
               them, the guidance on multi-element arrangements in EITF 00-21,
               Revenue Arrangements with Multiple Deliverables and SAB 104, was
               determined as not applicable in light of these facts. Moreover,
               the proceeds generated only partially cover our marketing
               expenses related thereto.

               Based on the foregoing, we respectfully advise the Staff that
               further disclosure in our future periodic filings regarding our
               Standard Plus Club is unwarranted as such program is an
               immaterial part of our business.

         c)    PRODUCT RETURNS: We permit our customers to return products to us
               within customer-specific limits in the event that they have
               overstocked their inventories. Overstocked returns pertain to
               inventory that is not defective, but rather new; that is not
               considered obsolete by the Company; and that the Company believes
               it can utilize. As is common in our industry, our customers'
               rights of overstock returns are generally limited to a specified
               percentage (averaging approximately 5%) of their annual purchases
               from us, thereby limiting their rights of return, both in terms
               of length of time and amount. Annual limits cannot be carried
               forward to the upcoming year. The Company accrues for returns as
               a percentage of sales, after giving consideration to recent
               returns history.

               The amount of overstock returns we have recorded in each of the
               three years presented in our Form 10-K are $38,641,000,
               $36,495,000 and $26,359,000 for 2004, 2003 and 2002,
               respectively.

     4.  GOODWILL AND OTHER INTANGIBLE ASSETS

         In connection with the Dana Engine Management ("DEM") acquisition, we
         had engaged Deloitte & Touche ("D&T") to perform a valuation of the
         other identified intangible assets acquired in the transaction. The
         valuation was completed by D&T and it identified two specific
         intangible assets: trademarks and customer relationships. An adjustment
         was made in the June 30, 2004 quarterly results to reflect the results
         of the report. At that time, our auditors, KPMG LLP, had reviewed the
         valuation report and were satisfied with the report.

         On September 27, 2004, we changed auditors to Grant Thornton LLP
         ("GT"). In connection with the quarterly review procedures performed as
         of September 30, 2004, GT reviewed the D&T report and the assumptions
         used therein. The valuation methodology selected by D&T was deemed
         reasonable and in accordance with generally accepted valuation
         principles. However, in reviewing the assumptions used, GT believed
         certain of the assumptions did not appear reasonable in regard to the
         customer relationship asset. Discussions were held with management, GT
         and D&T. The primary concern raised by GT centered on the assumption
         that income derived from the customer relationships would be reduced by
         lower margins being generated in the early post acquisition years
         resulting from inefficient operations prior to the full integration of
         the businesses. It was GT's opinion that the value of a customer
         relationship should not be reduced by inefficiencies from the early
         years. A revised analysis was prepared by the Company to eliminate
         these inefficiencies and resulted in an additional $2 million increase
         in the value of the customer relationships.

                                      -4-
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     5.  CONTROLS AND PROCEDURES

         We agree with the Staff's position that the certifications provided by
         our principal executive officer and principal accounting officer should
         have stated that management's conclusion regarding the effectiveness of
         our disclosure controls and procedures is AS OF THE END OF THE PERIOD
         COVERED BY THE ANNUAL REPORT. However, we respectfully request that the
         Staff allow us to make such change in future filings instead of
         amending our Form 10-K. We advise the Staff that the failure to include
         such language in our Form 10-K was merely an oversight and was not done
         intentionally. We do not believe that the error is material to an
         investment decision or is necessary for the protection of investors.

         In response to the Staff's comments, the Company acknowledges that:

         o     the Company is responsible for the adequacy and accuracy of the
               disclosure in the filing;
         o     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
         o     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.

Please contact the undersigned at 718-392-0200 or Carmine Broccole at
718-316-4940, if you have any questions regarding this matter.

                                 Very truly yours,

                                 /s/ JAMES J. BURKE
                                 --------------------
                                 James J. Burke
                                 Chief Fi