SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                  May 22, 2007
Ms. Merilee Raines
Corporate Vice President and Chief Financial Officer IDEXX Laboratories, Inc. One IDEXX Drive  Westbrook, Maine   04092

Re: IDEXX Laboratories, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2006   Filed on March 1, 2007
Form 10-Q for Fiscal Quarter Ended March 31, 2007  Filed on May 2, 2007
 File No. 000-19271
Dear Ms.  Raines:

We have reviewed your filing and have the following comments.  We have
limited our review of your filing to the issues we have addressed in our comments.  In our
comments, we ask you to provide us with in formation so we may better understand your
disclosure.  Please be as deta iled as necessary in your expl anation.  After reviewing this
information, we may raise additional comments.   Please understand that the purpose of our re view 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.
 Item 7.  Management’s Discussion and Analys es of Financial Condition and Results of
Operations, page 20
 1. The company reiterated here the policy notes  included in the financial statements.
Critical Accounting Polices should suppl ement, not duplicate, the accounting
policies disclosed in the notes to the fina ncial statements.  Please provide us in a
disclosure-type format the company's anal ysis of the judgments and uncertainties
involved in applying these accounting principl es at a given time, and the potential

Ms. Merilee Raines
IDEXX Laboratories, Inc. May 22, 2007 Page 2
 impact on your financial statements of the variability that is reasonably likely to
result from their applicati on over time.  Disclosures expl aining the likelihood that
any materially different amounts would be reported under different conditions,
using different assumptions is consiste nt with the objective of Management’s
Discussion and Analysis.  See Release 33-8350.
 Revenue Recognition, pages 24-25

 2. Your disclosures related to estimates of items that reduce gross revenue such as
customer credits, award points, trade- in rights and other discounts could be
improved as follows:

• Disclose the nature and amount of each accrual at the balance sheet date.
• Disclose the factors that you consider in  estimating each accrual such as levels
of inventory in the distribution channel,  estimated remaining shelf life, price
changes from competitors and others as applicable.
• Disclose the major terms of material arrangements/agreements
• Disclose your policy with respect to  determining when a receivable is
recorded as a bad debt and ultimately written off.
• Disclose a roll forward of the liab ility for each estimate for each period
presented showing the following:
o Beginning balance,
o Current provision related to sales made in current period,
o Current provision related to sales made in prior periods,
o Actual returns or credits in current period related to sales made in
current period,
o Actual returns or credits in current period related to sales made in prior
periods, and
o Ending balance.
• In your discussion of results of opera tions for the period to period revenue
comparisons, discuss the amount of and reason for fluctuations for each type
of reduction of gross revenue (i.e. cust omer credits, award points, trade-in
rights and other discounts) including the e ffect that changes in your estimates
of these items had on your revenues a nd operations.  Provide your response in
a disclosure-type format.
 3. Please clarify your deferred revenue policy to indicate whether and to what extent
and how you use any type of systematic method to recognize revenue that has
been deferred.

Ms. Merilee Raines
IDEXX Laboratories, Inc. May 22, 2007 Page 3
 Liquidity and Capital Resources, page 39

 Contractual Obligations Table. Page 42

 4. You did not include interest payable on long-term debt in the contractual
obligation table, and it would appear that  these liabilities represent future legal
obligations.  Due to the signi ficant nature of these liab ilities to your business we
believe their inclusion in the contractua l obligation table wi ll provide investors
increased disclosure of your liquidity .  The purpose of Financial Reporting
Release 67 is to obtain enhanced disclosu re concerning a regist rant’s contractual
payment obligations and the exclusion of ordinary course items would be
inconsistent with the objec tive of the Item 303(a)(5) of Regulation S-K.  Based on
the above factors, please pr ovide us in disclosure-type  format revisions to your
contractual obligation table to include interest payable on long term debt.
 Consolidated Financial Statements

 Note 11. Commitments, Contingencies and Guarantees, page F-27

 5. Explain to us why not including informa tion about the legal proceeding initiated
by Cyntegra in June 2006 was considered appropriate.  We found no disclosures
included in your most recent periodic re port filed on May 2, 2007 related to this
matter.  SFAS 5 and SAB 92 require certain disclosures including a) disclosure of
the estimated loss, or range of loss, that is reasonably possible, or b) disclosure
that such an estimate cannot be made.  If an estimate cannot be made, the facts and circumstances that prevent management  from making such an estimate should
be disclosed.  Please provide us disclosure s in disclosure-type format that comply
with SFAS 5 and SAB 92 requirements. In addition, provide disclosures as
required by Item 103 of Regulation S-K in  disclosure-type format and proposed
disclosures to be included in your MD&A  about the contingency if you conclude
these disclosures are required.
 Note 16. Segment Reporting

6. Long-lived assets by geographic areas shoul d not include intangible assets.  Refer
to question 22 in the FASB Implementation Guide to FAS 131.  Provide us revised disclosure.  You may provide your current disclosure in addition to that
required by the standard.
 Exhibits 31.1 and 31.2

 7. In future filings please ensure that the certifications’ language is exactly the same
as the language required by Item 601 of Regulation S-K.  For example, do not

Ms. Merilee Raines
IDEXX Laboratories, Inc. May 22, 2007 Page 4
 replace the word “report” w ith “annual report” or “quart erly report” in paragraphs
1, 2, 3, and 4.   Please provide us revised ce rtifications in disclosure-type format.
 Form 10-Q March 31, 2007

 Condensed Consolidated Financial Statements

 Notes to Condensed Consolidated Financial Statements, page 6

 Note 2. Business Acquisitions, page 6

 8. Please provide us the analysis that form ed the basis for your conclusion that pro
forma information and disclosures rega rding acquisitions were not required.
Please give us a description of the factors that contributed to a purchase price that
resulted in the recognition of goodwill to be  included in future filings (paragraph
51b of FAS 141).  Please tell us why appa rently no amounts were allocated to any
customer relationships acquired and how that was consistent with SFAS 141 and
EITF 02-17.
 Item 2. Management’s Discussion and Analys es of Financial Condition and Results of
Operations, page 13

Liquidity and Capital Resources, page 20
 9. Your discussion of cash used by operations merely reiterates what is presented on
the statement of cash flows.  Cash wa s provided by operations for the years 2006,
2005 and 2004.  Please provide us expande d disclosure which discusses the
underlying reasons that cash was us ed in the first quarters.

*    *    *    *

 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 provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish your letter on E DGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing include all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Ms. Merilee Raines
IDEXX Laboratories, Inc. May 22, 2007 Page 5
  In connection with responding to our co mments, please provide, in your letter, 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 filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact Ibolya I gnat, Staff Accountant at  (202) 551-3656, or Lisa
Vanjoske, Assistant Chief Accountant, at ( 202) 551-3614 if you have questions regarding
the comments.  In this regard, do not he sitate to contact me, at (202) 551-3679.

Sincerely,   Jim B. Rosenberg Senior Assistant Chief Accountant