SecProbe.io

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      August 15, 2005

Mail Stop 4561

VIA U.S. MAIL AND FAX 1-603-332-7429

Ms. Suzanne Verrill
Chief Financial Officer
Brandpartners Group, Inc.
10 Main Street
Rochester, NH 03839

RE:	Brandpartners Group, Inc.
Form 10-K for the year ended December 31, 2004
Form 10-Q for the quarters ended March 31, 2005 and June 30, 2005
File no. 00-16530

Dear Ms. Verrill:

We have reviewed the above referenced filings and have the
following
comments.  We have limited our review to only your financial
statements and related disclosures and will make no further review
of
your documents.  In our comments, we may ask you to provide us
with
information so we may better understand your disclosure.  Please
be
as detailed as necessary in your explanation.  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 10K for the fiscal year ended December 31, 2004

Notes to Consolidated Financial Statements, General

1. We note on page 11 that the Company is organized into three
separate business units.  Tell us how you considered SFAS 131 in
determining your reportable segments information.

Note B Summary of Significant Accounting Policies, Revenue
Recognition, page 45

2. Please explain to us the major terms for each type of contract
where you recognize revenue using a percentage-of-completion
method
including, but not limited to, the duration, the billing and
payment
requirements and the rights of cancellation and refund that you
considered in your determination of how to recognize revenue.
Disclose the type of contracts based on the methods of pricing
(e.g.,
fixed-price or lump-sum, cost-type, time-and-material, unit-
price).

3. We understand that you are using input measures to determine
percentage of completion. Please advise us whether you use this
measure of performance for fixed price service contracts. If so,
generally for fixed price service contracts that are not within
the
scope of SOP 81-1, we believe that an output methodology is more
appropriate than an input methodology as the latter could result
in
an inappropriate acceleration of revenue.  If applicable, clarify
to
us the basis for your use of inputs rather than outputs to measure
performance under fixed price contracts.  Your response should
address but need not be limited to the following:

* whether or not you incur significant start up costs under these
contracts and how that effects revenue recognition;
* your realization rates under these contracts and your charge off
experience under these contracts;
* whether or not upon contract termination, the termination fee
owed
to you would be the amount due to you if this had been a time and
materials contract.

4. We note on page six that you offer services independently or as
a
holistic package. Please tell us how you have considered the
provisions of EITF 00-21 for each of the deliverables included in
the
holistic package.

Note H - Long Tem Debt, page 58

5. With respect to the forgiveness of debt disclosed in note H(1),
please explain to us how you considered footnote 1 in APB Opinion
26
in determining that gain recognition was appropriate. Often the
forgiveness of principal or accrued interest on loans among
related
parties is, in substance, capital transactions.

*    *    *    *
As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
file your response on EDGAR.  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 filings 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or in response
to
our comments on your filings.

You may contact Kelly McCusker, Staff Accountant, at (202) 551-
3433
or the undersigned at (202) 551-3414 if you have questions.

						Sincerely,

      Jorge Bonilla
      Senior Staff Accountant

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Ms. Verrill
Brandpartners Group, Inc.
August 15, 2005
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