SecProbe.io

August 6, 2012

Via E -mail
Mr. Jonathan Ayers
Chief Executive Officer and President
IDEXX L aboratories, Inc .
One IDEXX Drive
Westbrook, M E  04092

Re: IDEXX Laboratories, Inc.
Form 10-K for the Y ear Ended December 31 , 2011
Filed February 17, 2012
File No. 000-19271

Dear Mr. Ayers :

We have reviewed your filing  and have the following comment .  In our comment , we ask
you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by providing the requested
information or by advising us when you will provide the requested response.   If you do not
believe the comment applies to your facts and circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that key s
your response  to our comment .

After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

Management’s Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies and Estimates
Revenu e Recognition, page 31

1. It appears, based on the information in the tables presented on page 33, that your Up -
Front Customer Loyalty Programs experienced significant volume growth in 2010 and
2011.  Please address the following comments:
 Please summarize for us the terms of your Up -Front Customer Loyalty Programs.  In
your response, please clarify whether your incentives to customers upon entering into
agreements are in the form of cash payments and, if so, whether they are refundable.
If not, please expl ain what incentives are provided.  Also clarify how these incentives
are applied against the future delivery of products or provision of services.
 Please provide us your analysis supporting why capitalization of these incentives as
customer acquisition cos ts is appropriate and reference for us the authoritative
literature you rely upon to support your accounting.  To the extent you rely in part on

Mr. Jonathan Ayers
IDEXX L aboratories, Inc .
August 6, 2012
 Page 2

 the guidance in ASC 605 -50-25-3, please explain to us how your arrangements are
“single exchange transactions” as contemplated in that guidance and how your
arrangements are not precluded from accounting under ASC 605 -50 as stipulated in
the scope paragraph in ASC 605 -50-15-3.
 Please provide us a sample of journal entries for a reasonable hypothetical transaction
under your Up -Front Customer Loyalty Program that demonstrates from contract
inception to completion how you record revenue and costs, including the operation of
your incentives.  In this regard, it is unclear how you generated $21.3 million in
credits to y our accrued customer programs liability account in 2011 when only $4.0
million appears to be recorded as a debit to revenues.  It is also unclear whether and,
if so, how the $35.6 million in IDEXX Points redeemed and credits issued in 2011
relates to your Up-Front Customer Loyalty Programs.
 Please tell us your consideration for discussing your apparent increased use of these
loyalty programs in your results of operations and liquidity discussions.

We urge all persons who are responsible for the accuracy an d adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relati ng to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment , please provide a written statement from the company
acknowledging that:

 the company is responsible for th e 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 respect 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.

Please contact Kei Nakada, Staff Accountant, at (202) 551 -3659 or Mark Brunhofer,
Senior Staff Accountant, at (202) 551 -3638  if you have questions regarding the comments.  In
this regard , do not hesitate to contact me  at (202) 551 -3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant