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CORRESP
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CORRESP

 September 30, 2013

Jim B. Rosenberg

 Senior Assistant Chief Accountant

Division of Corporation Finance

 United States Securities and
Exchange Commission

Re:
IDEXX Laboratories, Inc.

Form 10-K for Fiscal Year Ended December 31, 2012

Filed on February 19, 2013

File No. 000-19271

 Dear Mr. Rosenberg:

This letter sets forth below the detailed responses of IDEXX Laboratories, Inc. and its wholly-owned and majority-owned subsidiaries (collectively,
“we”, “us” or the “Company”) to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in its letter to the Company dated September 9, 2013 with
respect to the above-referenced Form 10-K (the “2012 Form 10-K”). In responding to the Staff’s comments, each of our responses is preceded by a reproduction of the corresponding numbered or bulleted Staff comment. This letter has been
filed with the Commission as correspondence through EDGAR.

 We understand that you will be reviewing our responses and may have additional comments. We
welcome any questions you may have and thank you for your attention to our filing. Please feel free to contact our Chief Financial Officer at the telephone number provided at the end of this letter.

Form 10-K for the Year Ended December 31, 2012

Business

 Patents and Licenses, page 10

 Comment:

1.
Please provide us proposed disclosure to be included in future periodic reports that clarifies the extent of the importance to the company of each patent and license listed. For patents expiring in 2014 and 2015,
provide us proposed disclosure to be included in MD&A in future periodic reports that indicates the expected effects on future operations and financial position of the expirations including potential decreases in revenues and asset
impairments.

 Mr. Jim B. Rosenberg

United States Securities and Exchange Commission

September 30, 2013

 Page 2

 Response:

The Company’s listed patents and licenses of patents and technologies from third parties are considered important to the Company for a
variety of reasons including, among other things, our ability to differentiate our products, defend our proprietary rights and technologies, and develop and protect our competitive position. The financial and operational impact of the expiration of
these patents or licenses, however, is mitigated by a range of factors including the Company’s brand strength and reputation in the marketplace, the breadth of our overall product offerings, the quality of our offerings and customer support,
our sales force, and our innovative product pipeline. Therefore, while the patents and licenses listed in the Company’s 2012 Form 10-K are important to the Company, the expiration of these patents or licenses, individually or in the
aggregate, is not expected to have a material effect on the Company’s financial position or future operations.

 In response to
the Staff’s comments, the Company intends to include in its future filings, beginning with the Form 10-K for the fiscal year ending December 31, 2013 (the “2013 Form 10-K”), expanded disclosure in the Company’s Business
section related to its patents and licenses to clarify further the extent of the importance of patents and licenses to the Company, similar to the following (changes in bold type face), based on the Patents and Licenses
disclosure on page 10 in the Company’s 2012 Form 10-K:

 “We actively seek to obtain patent protection in the U.S. and
other countries for inventions covering our products and technologies. We also license patents and technologies from third parties. Patents and licenses of patents and technologies from third parties are considered important to the Company based
on a variety of factors including providing protection for the Company’s inventions and other proprietary intellectual property, affording protection from competitors in certain markets, enabling the use of more effective and efficient
technologies in the development and production of our products and offerings, strengthening the Company’s reputation and standing among customers, employees and key suppliers, and acting as a deterrent against counterfeiters, imitators and
other copiers of technologies.

 Important patents and licenses include:

•

Exclusive licenses from the University of Texas and Tulane University to patents that expire in 2017 and 2019, respectively, relating to reagents and methods for the detection of Lyme disease utilized in certain of our
SNAP® products and a reference laboratory diagnostic test;

•

A patent concerning the Colilert®-18 product that expires in 2014;

•

A patent concerning the Quanti-Tray® product that expires in 2014;

•

A patent that relates to certain methods and kits for simultaneously detecting antigens and antibodies, which covers certain of our SNAP® products, including our
canine and feline combination tests, that expires in 2014;

 Mr. Jim B. Rosenberg

United States Securities and Exchange Commission

September 30, 2013

 Page 3

•

Patents covering various reagents, kits and/or immunoassays for detecting FIV antibodies utilized in certain of our SNAP® products that expire beginning in 2014;

•

An exclusive license from Boehringer Ingelheim to certain patents covering reagents and methods for detecting PRRS that expire in 2014;

•

An exclusive license from Cornell University to patents covering methods for detecting BVDV that expire beginning in 2017;

•

Patents concerning the SNAP® immunoassay platform that expire in 2015; and

•

Patents concerning Catalyst Dx® consumables that expire beginning in 2023.

While we consider these proprietary technology rights to be important to the Company, a range of factors help to mitigate the future
effects of patent and license expiration on our results of operations and financial position. These factors include our brand strength and reputation in the marketplace; the breadth, quality and integration of our product offerings; our existing
customer relationships and our customer support; our sales force; the applicable regulatory approval status for certain products; our continued investments in innovative product improvements that often result in new technologies and/or additional
patents; our significant know-how, scale and investments related to manufacturing processes of associated product offerings; and certain supply arrangements for consumables that are compatible with our instruments. In addition, we already face
notable competition in certain areas as other companies have been successful in bringing competitive products to market, despite the protections afforded by these proprietary technology rights. See “Part II. Item 7. Management’s
Discussion and Analysis of Financial Condition and Results of Operations –Effects of Certain Factors on Results of Operations — Effects of Patent Expiration” for a discussion of expected effects on future operations and financial
position of patents and licenses expiring within two years of this report.

 To the extent some of our products may now, or in the
future, embody technologies protected by patents, copyrights or trade secrets of others, we may be required to obtain licenses to such technologies in order to continue to sell our products. These licenses may not be available on commercially
reasonable terms or at all. Our failure to obtain any such licenses may delay or prevent the sale of certain new or existing products. See “Part I, Item 1A. Risk Factors.””

In response to the Staff’s comments, the Company also intends to include in its future filings, beginning with the 2013 Form 10-K, new disclosure in Management’s Discussion and Analysis of Financial Condition and Results of Operations –Effects of Certain Factors on Results of Operations related to the effect of the
expected expirations of patents and licenses within two years of the applicable report on the Company’s future operations and financial position, similar to the following (new text in bold type face):

 Mr. Jim B. Rosenberg

United States Securities and Exchange Commission

September 30, 2013

 Page 4

“Effects of Patent Expiration — Although the Company has several patents and licenses of patents and technologies from
third parties expected to expire during 2014 and 2015, the expiration of these patents or licenses, individually or in the aggregate, is not expected to have a material effect on the Company’s financial position or future operations due to a
range of factors including our brand strength and reputation in the marketplace; the breadth, quality and integration of our product offerings; our existing customer relationships and our customer support; our sales force; the applicable regulatory
approval status for certain products; our continued investments in innovative product improvements; and our significant know-how, scale and investments related to manufacturing processes of associated product offerings.”

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Policies and Estimates

Revenue Recognition, page 35

 Comment:

2.
Please provide us proposed disclosure to be include in future periodic reports that explains the use of “net” in the table of “revenue reductions recorded, net” at the bottom of page 37 and in the
line items “Revenue reductions for Customer Loyalty Programs, net”, “Revenue reductions for IDEXX VetLab® Instrument Marketing Programs, net” and “Revenue reductions
for Other Customer Programs, net” in the table at the top of page 38. In this regard, address what is being netted and the amounts.

Response:

 In response to the
Staff’s comments, the Company intends to include in its future filings, beginning with the 2013 Form 10-K, expanded disclosures related to revenue reductions for our customer programs where revenue reductions are presented as a net number.
Specifically, we intend to expand disclosure in future filings to clarify the revenue reductions that are presented as a “net” number for our Customer Loyalty Programs, IDEXX VetLab®
Instrument Marketing Programs and Other Customer Programs. The expanded disclosures will be similar to the following (changes in bold type face) based on the Critical Accounting Policies and Estimates – Revenue Recognition –
Customer Programs beginning on page 36 and F-13 in the Company’s 2012 Form 10-K:

 Mr. Jim B. Rosenberg

United States Securities and Exchange Commission

September 30, 2013

 Page 5

 “CRITICAL ACCOUNTING POLICIES AND ESTIMATES

Revenue Recognition

Customer programs. We record reductions to revenue related to customer marketing and incentive programs, which include
end-user rebates and other volume-based incentives. Incentives may be provided in the form of IDEXX Points, credits or cash and are earned by end-users upon achieving defined volume purchases or utilization levels or upon entering an agreement to
purchase products or services in future periods. The summary of revenue reductions presented below reflects all revenue reductions recorded for the year for each particular program. These amounts are presented on a net basis when applicable,
which account for any differences between estimates and actual incentives earned for the relevant customer marketing or incentive program. These differences have been insignificant in all quarterly or annual periods. Our most significant
customer programs are categorized as follows:

 Customer Loyalty Programs. Our customer loyalty programs offer customers the
opportunity to earn incentives on a variety of IDEXX products and services as those products and services are purchased and utilized. Revenue reductions related to customer loyalty programs are recorded based on the actual issuance of incentives,
incentives earned but not yet issued and estimates of incentives to be earned in the future based on applicable product inventories held by distributors at the end of the period.

Up-Front Customer Loyalty Programs. Our up-front loyalty programs provide incentives to customers in the form of cash payments or IDEXX
Points upon entering multi-year agreements to purchase annual minimum amounts of future products or services. If a customer breaches its agreement, it is required to refund a prorated portion of the up-front cash or IDEXX Points. These incentives
are considered to be customer acquisition costs and are capitalized and recognized as a reduction to revenue over the term of the customer agreement. If these up-front incentives are subsequently utilized to purchase IDEXX VetLab® instruments, digital radiography systems or Cornerstone® practice management systems, product revenue and cost is deferred and recognized
over the term of the customer agreement as products and services are provided to the customer. We monitor customer purchases over the term of their agreement to assess the realizability of our capitalized customer acquisition costs. For the years
ended December 31, 2012, 2011 and 2010, impairments of customer acquisition costs were immaterial.

 IDEXX VetLab® Instrument Marketing Programs. Our instrument marketing programs require the customer to enroll at the time of instrument purchase and offer customers the opportunity to earn incentives in
future periods based on the volume of the products they purchase and utilize over the term of the program.

Mr. Jim B. Rosenberg

 United States Securities and Exchange Commission

September 30, 2013

 Page 6

These arrangements are considered MEAs in accordance with our revenue recognition policy stated above. Revenue reductions related to
instrument marketing programs are recorded based on an estimate of customer purchase and utilization levels and the incentive the customer will earn over the term of the program. Our estimates are based on historical experience and the specific
terms and conditions of the marketing program and require us to apply judgment to approximate future product purchases and utilization. Differences between our estimates and actual incentives earned are accounted for as a change in estimate. These
differences were not material for the years ended December 31, 2012, 2011 and 2010. At December 31, 2012, a 5% change in our estimate of future customer utilization would increase or reduce revenue by approximately $0.3 million.

Reagent Rental Programs. Our reagent rental programs provide our customers the right to use our instruments in consideration for
multi-year agreements to purchase annual minimum amounts of consumables. No instrument revenue is recognized at the time of instrument installation. We recognize a portion of the revenue allocated to the instrument concurrent with the future sale of
consumables. We determine the amount of revenue allocated from the consumable to the instrument based on VSOE and determine the rate of instrument revenue recognition in proportion to the customer’s minimum volume commitment. The cost of the
instrument is reclassified from inventory to equipment and charged to cost of product revenue on a straight-line basis over the term of the rental agreement.

IDEXX Points may be applied against the purchase price of IDEXX products and services purchased in the future or applied to
trade receivables due to us. IDEXX Points that have not yet been used by customers are classified as a liability until use or expiration occurs. We estimate the amount of IDEXX Points expected to expire, or breakage, based on historical expirations
and we recognize the estimated benefit of breakage as IDEXX Points are issued to customers. On November 30 of each year, unused IDEXX Points earned before January 1 of the prior year generally expire and any variance from the breakage
estimate is accounted for as a change in estimate. This variance was not material for the years ended December 31, 2012, 2011 and 2010.

Future market conditions and changes in product offerings may cause us to change marketing strategies to increase or decrease
customer incentive