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      December
        19, 2005

      Securities
        and Exchange Commission

      450
        Fifth
        St., N.W.

      Washington,
        D.C. 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 enclosed responses that correspond directly to the numbered
        comments in the Commission’s letter of December 1, 2005.

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

            1.

              Your
                response to our prior comment does not appear to address directly
                or
                completely our request for additional information relating to your
                analysis of SFAS 131. Please address the following additional comments
                relating to your conclusion that you have only one reportable
                segment:

            ·

              Please
                clarify to us, using each of the specific characteristics set forth
                in
                paragraph 10 of FAS 131, how you determined that your Merchandising,
                Creative and Design/Build business units are not operating
                segments.

      Response:
        Our
        customers are financial institutions, namely banks and credit unions. This
        is
        our only market at the present time. There is one set of resources within
        the
        Company, which are used to fulfill the needs of these customers. Our marketing
        effort is directed at the financial services marketplace, not on our product
        and
        service offerings. A “menu” of product/service offerings is provided to our
        customers to meet their needs.

      To
        respond to the definitions located in Paragraph 10 of FAS 131:

            10.

              “An
                operating
                segment
                is
                a component of an enterprise:

            a.

              That
                engages in business activities from which it may earn revenues and
                incur
                expenses (including revenues and expenses relating to transactions
                with
                other components of the same enterprise),. .
                .”

      We
        work with one market earning revenues and incurring expenses at a corporate
        level. The Company’s product offerings use one set of resources within the
        Company. The support structure is integrated in such a way that the customer
        sees only the Company as a whole and not the individual
        pieces.

                “b.

                Whose
                  operating results are regularly reviewed by the enterprise’s chief
                  operating decision maker to make decisions about resources to be
                  allocated
                  to the segment and assess its performance, and. .
                  .”

      There
        is one set of resources used within the Company to support its product and
        service offerings. The Company’s “chief operating decision maker” views the
        structure of the Company as a single operating entity.

                “c.

                For
                  which discrete financial information is
                  available.”

      Because
        the Company has one set of resources, discrete financial information for
        each of
        the products and services would have to be done on an allocation basis. The
        complexities of the Company’s operations are such that any such allocation would
        be more arbitrary than exact, and the results would not be meaningful to
        readers
        of the financial statements.

            ·

              We
                note your assertion that your operating segments exhibit similar
                long-term
                financial performance, and therefore, are combined into one segment.
                Please explain to us how your operating segments met each of the
                aggregation criteria outlined in paragraph 17 of SAFAS 131. Also,
                reconcile your conclusions with the disclosure on page 13 that the
                business units have different business models and the apparent differences
                in gross profit discussed on page 14.

      Response:
        The
        Company’s product and service offerings are monitored to better service the
        industry and to determine if the business environment has changed. In future
        filings, we will adjust our terminology to more accurately reflect the
        activities of the Company.

      Using
        the aggregation criteria in Paragraph 17:

            a.

              The
                nature of the products and services

      A
        bank branch requires renovation. As part of fulfilling the customer’s needs, a
“new look” is developed which incorporates various product offerings, including
        merchandising fixtures, interior design, furniture and a new graphics campaign.
        Internally, similar resources are used to develop and deliver the contracted
        for
        products and services. The products and services are similar in that they
        are
        directed at a very particular type of customer with identifiable and distinct
        needs. Externally, the customer has one contact with the Company and only
        sees
        the results.

            b.

              The
                nature of the production process

      The
        Company is not a manufacturer. The Company pulls various resources together
        to
        provide products and services to its customers. The “production process” is
        similar throughout the entire Company.

            c.

              The
                type or class of customer for their products and
                services.

      The
        Company deals with one type of customer - financial
        institutions.

            d.

              The
                methods used to distribute their products or provide their
                services.

      The
        Company provides all its products and services to all of its customers on
        a
        contract-driven basis specific to the individual customer.

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            e.

              If
                applicable, the nature of the regulatory environment, for example,
                banking, insurance, or public utilities.

      This
        is not applicable to the Company.

      BrandPartners
        provides a wide range of product and service offerings to the financial services
        industry. This is the only market which the Company services. While the product
        and service offerings do have different profit goals, they are supported
        by a
        single set of resources within the Company. The chief decision maker determines
        how the set of resources will be allocated to those products and/or services.
        In
        servicing a single marketplace, the Company monitors the needs of that
        marketplace through the tracking of which product/service offerings are
        successful.

            2.

              We
                note your response to our prior comment five. Please tell us the
                debtors’
                stock ownership in BrandPartners Group, Inc. before and after the
                forgiveness of debt. Also, tell us whether the debtors had any function
                with the Company subsequent to the forgiveness of
                debt.

      The
        debtor’s stock ownership in BrandPartners Group prior to and after the
        forgiveness of debt was 756,250 shares each, or a total of 1,512,500 shares.
        This was less than 5% of the total stock outstanding. The debtors have had
        no
        function with the Company subsequent to the forgiveness of debt.

      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.

      Suzanne
        Verrill

      Chief
        Financial Officer

      cc: Baratta
        & Goldstein

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