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      Unassociated Document

    August
      29, 2005

    Securities
      and Exchange Commission

    450
      Fifth
      Street, N.W.

    Washington,
      DC 20549

    Attn:
      Jorge Bonilla, Senior Staff Accountant

            RE:
            BrandPartners Group, Inc.
              (the
              “Company”) Form 10-K for the Year Ended December 31, 2004

            Form 10-Q for the Quarterly
              Periods
              Ended March 31, 2005 and June 30, 2005

            File No.
              00-16530

    Dear
      Mr.
      Bonilla:

    On
      behalf
      of the Company, we enclose responses that correspond directly to the numbered
      comments in the Commission’s letter of August 15, 2005.

    Form
      10-K for the Fiscal Year Ended December 31, 2004

    Notes
      to Consolidated Financial Statements, General

            1.

              We
                note that 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.

    Response:
      Management
      does not consider the three separate business units to be operating segments.
      According to the definition of an “operating segment,” the primary criteria
      are:

            a.

              The
                business segment earns revenues and incurs
                expenses

            b.

              The
                enterprise’s chief operating decision maker makes decisions about
                resources to be allocated to the
                segment.

            c.

              Individual
                financial information is
                available.

    At
      BrandPartners Group, resources are used by all business units and are not
      segregated to a specific segment. In a typical project, a customer may use
      the
      services of all three business units in the process of completing a project.
      The
      three business units address all the phases of the overall project, from
      determining which building site to use, to the design/building of the facility,
      to branding/corporate identity implementation, to the merchandising fixtures
      as
      part of the branding program for the location, and to the collateral for the
      location which further defines the marketing message. These functions have
      been
      defined in order to provide a more efficient method of servicing our customers
      and not as independent operating segments.

          Securities
            and Exchange Commission

          August
            29, 2005

          Page
            2

     In
      accordance with paragraph 17 of SFAS 131, although the Company utilizes the
      three business units, the operating segments exhibit similar long-term financial
      performance, and therefore, are combined into one segment. Furthermore,
      according to paragraph 73 of SFAS 131, the Board believed “that separate
      reporting of segment information will not add significantly to an investor’s
      understanding of an enterprise if its operating segments have characteristics
      so
      similar that they can be expected to have essentially the same future
      prospects.” This is the case with BrandPartners Group.

            2.

              Please
                explain to use 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).

    Response:
      The
      percentage-of-completion method of accounting is used for our design and
      construction management projects. In a typical contract, a financial institution
      contracts with BrandPartners to provide design and/or construction management
      services. A contract has the following attributes:

            a.

              Duration
                from a few to several months - majority less than 1
                year

            b.

              Deposit
                is requested at time of
                signing

            c.

              Invoicing
                after initial deposit is based upon work
                performed

            d.

              Cancellation
                is permitted with reimbursement for work performed to
                date

    BrandPartners
      provides construction management services. BrandPartners contracts with a
      general contractor, who then makes arrangements with and is responsible for
      various subcontractors. BrandPartners may also contract with additional
      subcontractors to provide specialized services such as millwork or bank
      equipment. At the beginning of the contract, an initial deposit is requested
      from the customer. The deposits are recorded on the balance sheet as an
      overbilling since no work has been performed. As the work is performed, revenue
      is recognized based upon the percentage-of-completion method. The criteria
      for
      percentage-of-completion recognition is based upon the invoices received (costs
      incurred) from the various contractors for work performed to date, including
      materials and labor costs incurred to date. These costs are reviewed by the
      project manager in charge of the project to determine accuracy and completeness.
      Vendor invoices are also compared against the budget to assure that actual
      work
      is being performed within agreed budgetary limits. For the revenue calculation,
      the costs as a percentage of the entire budget for the project are used to
      calculate and recognize revenue. Revenue is thus recognized to the extent of
      the
      work actually completed. The customer is billed according to the terms of the
      contract. Billing to customers in many instances is restricted to a 20-day
      cycle, while revenue recognition is based upon the period costs incurred to
      date.

    Most
      contracts are fixed price contracts. This includes both the contracts with
      the
      customer and with the contractors. Adjustments may be made to the original
      agreement through change orders, which are beyond the original scope of the
      project. In the entire history of the company, no refunds have ever been
      required since these projects are thoroughly researched and agreed to before
      the
      beginning of the project. If a project were to be cancelled, under the terms
      of
      the AIA contract, the customer is obligated to pay for all work performed to
      date.

          Securities
            and Exchange Commission

          August
            29, 2005

          Page
            3

            3.

              We
                understand that you are using input measure 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 use 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 affects 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.

    Response:
      We
      actually use proportional performance for determining the percentage of
      completion. Invoices from the general contractor and other subcontractors for
      actual work performed are used as the basis for calculating the percentage
      of
      completion for the project. The above invoices are verified and approved by
      the
      project manager to assure that they are complete and correct. We do not have
      any
      start-up costs on our projects - the costs are expensed as incurred. As noted
      above, we provide construction management services and pay the general
      contractor for work after it is performed. In future submittals, we will change
      the wording in the description to be more reflective of the actual
      process.

            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 in the holistic
                package.

    Response:
      BrandPartners works with its customers to provide solutions. The “solution”
      might consist of a new bank branch (designed and built by the construction
      management business unit), which contains merchandising fixtures (i.e. wall
      frames, kiosks), provided by the merchandising business unit. Those same
      merchandising fixtures might contain posters and brochures created by the point
      of sale business unit. In accordance with EITF 00-21, the revenue recognition
      for each product is determined by the nature of the product. For example, branch
      construction revenue is based upon percentage-of-completion. The revenue for
      the
      merchandising fixtures and for the posters and brochures in those merchandising
      fixtures is recognized upon the delivery and/or installation of the products.
      The Company gives its customers the opportunity to take advantage of any and
      all
      product offerings without reference to any specific business unit. The internal
      mechanism to recognize revenue and its associated costs is based upon the nature
      of the product being provided.

          Securities
            and Exchange Commission

          August
            29, 2005

          Page
            4

    Note
      H
      - Long Term 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.

    Response:
      In
      January of 2001, the former shareholders of Willey Brothers, Inc. sold their
      stock to BrandPartners Group, Inc. As part of the agreement, the former
      shareholders were paid a combination of cash and BrandPartners stock, and were
      issued subordinated promissory notes. In January of 2004, the former
      shareholders agreed to the cancellation and forgiveness of the debt related
      to
      the notes. At the time, the former shareholders had no function with the Company
      other than to serve as consultants when requested. In accordance with FAS 57,
      we
      determined that as they were not part of management and had no control over
      the
      Company nor could they significantly influence the management nor the operating
      policies of the Company to the extent that one of the parties might be prevented
      from fully pursuing its own separate interests, they were, therefore, not
      considered related parties, and the forgiveness of debt occasioned by the
      January 2004 agreement was treated as a gain.

    In
      connection with the foregoing responses, the Company acknowledges
      that:

            ·

              It
                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

            ·

              It
                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.

    Should
      you have any questions or would like to further discuss any of the responses
      contained herein, please do not hesitate to contact the
      undersigned.

    Sincerely,

    BRANDPARTNERS
      GROUP, INC.

    /s/
      Suzanne Verrill

    Suzanne
      Verrill

    Chief
      Financial Officer

    cc:
      Baratta & Goldstein