SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 4720

         May 20, 2010

Conan R. Deady
Corporate Vice President, General Counsel and Secretary
Idexx Laboratories, Inc.
One Idexx  Drive
Westbrook , Maine 04092

Re:   Idexx Lab oratories, In c.
 Form 10 -K for the Fiscal Year Ended December 31, 200 9
 Filed February 19, 2010
 File Number:  000-19271

Dear M r. Deady:

We have reviewed your filing and have the following comment s.  In our
comment s, we ask you to provide us with information  to better understand your
disclosure. The information you provide should show us what the revised disclosure will
look like and identify the annual or quarterly filing, as applicable, in which you intend to
first include it. If you do not believe that rev ised disclosure is necessary, explain the
reason in your response. After reviewing the information provided, we may raise
additional comments and/or request that you amend your filing.

 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 comment or on any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.

Conan R. Deady
Idexx Laboratories, Inc.
May 20, 2010
Page 2

Annual Report on Form 10 -K

Item 1. Business

Production and Supply, page 9

1. You have disclosed that  you purchase some products, raw materials and
components from a single supplier.  Please identify your sole source suppliers,
describe the material terms of the supply agreement and file the agreements as
exhibits.  To the extent you believe you are not s ubstantially dependent on these
agreements, please provide your analysis supporting your determination.

2. Please describe the material terms of your supply agreements with Ortho -Clinical
Diagnostics, Inc.

Patents and Licenses, page 9

3. Please identify the products or classes of products related to patents related to the
detection of Lyme disease and the detection  of FIV antibodies.

4. Please describe the material terms of your agreements with Tulane  University , the
University of Texas, Boehringer Ingelheim and Cornell University and identify
the products or class of products related to these license agreements.  Please either
file th ese agreements as exhibits or provide us with an analysis supporting your
determination that you are not substantially dependent on these agreements.

Government Regulation, page 11

5. We note your statement that “compliance with an extensive regulatory process is
required in connection with marketing diagnostic products in Japan, Germany, the
Netherlands and many other countries.” Please expand your disclosure to include
a more detailed  discussion of the regulatory process es in those countries and
others outside the United States where you currently market your products, to the
extent that your sales in these countries are material.

Item 1A. Risk Factors

Various Government Regulation s Could Limit or Delay Our Ability to Market and Sell
Our Products, page 14

6. To the extent known,  please expand your disclosure concerning the FTC’s
investigation to state the actual practices you have engaged in that are at issue,
including which products  they concern, and what potential penalties you will be

Conan R. Deady
Idexx Laboratories, Inc.
May 20, 2010
Page 3

subject to if the FTC concludes that you have violated Section 5 of the Federal
Trade Commission Act .

Definitive Proxy Statement on Schedule 14A

Nominating and Governance Committee , page 8

7. Your disclosure concerning diversity on page 9 does not include a discussion of
how the Nominating and Governance Committee has implemented this policy  or
how the Committee assesses its effectiveness. Please revise your disclosure to
include this information. We refer you to Item 407(c)(2)(vi) of Regulation S -K.

Election of Directors, page 17

8. Please identify  the specific experience, qualifications, attributes or skills that led
to the conclusion that each person should serve as a director as required by Item
401(e) of Regulation S -K.  Please note that your discussion on page 8 is not
sufficient as the item requires a discussion of each individual’s experience,
qualifications, attributes or skills, as opposed to a discussion of the board
members’ collective experience, qualifications, at tributes or skills.

Compensation Discussion & Analysis, page 22

9.  We note your discussion of the establishmen t of the bonus pool on page 27.
Please disclose the amount of the bonus pool and  confirm that each individual’s
goals were used to determine the portion of the pool awarded to each individual as
a bonus.

10. Please revise the discussion of the annual cash bonus awards to discuss the
Committee’s overall assessment of each named exe cutive officer’s performance
based on the individual goals identified.  Your discussion should address the
extent to which the Committee believes that each named executive officer,
achieved, over achieved or under achieved his or her goals, any significant  factors
considered in making the assessment and the percentage of the bonus pool
awarded to each named executive officer.

* * * *

 Please provide us the information requested  within 10 business days or tell us
when you will provide us with a response.  Please furnish a cover letter with your response
that keys your response to our comments.  Detailed cover letters greatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

Conan R. Deady
Idexx Laboratories, Inc.
May 20, 2010
Page 4

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure i n the filing to be certain that the filing include all information required under
the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the company and its
management a re 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 your letter, a
statement from the company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in
the filing;

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respec t to the filing;
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 Enforceme nt has access to all
information you provide to the staff of the Division of Corporation Finance in our review
of your filing or in response to our comments on your filing.

Please contact Scot Foley  at (202) 551 -3383, Suzanne Hayes, Branch Chief, at
(202) 551 -3675 or me at (202) 551 -3715 with any questions.

        Sincerely,

        Jeffrey P. Riedler
        Assistant Director