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CORRESP
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      Natuzzi S.p.A. Correspondence

      October
        10, 2005

                Mr.
                  Rufus Decker

                Accounting
                  Branch Chief

                Division
                  of Corporation Finance

                United
                  States Securities and Exchange Commission

                100
                  F Street, N.E.

                Washington,
                  D.C. 20549

                U.S.A.

                  Natuzzi
                    S.p.A.

                Re:

                  Form
                    20-F for the fiscal year ended December 31, 2004

                  Filed
                    June 30, 2005

                  SEC
                    File No. 1-11854

      Dear
        Mr. Decker:

      By
        letter dated dated September 26, 2005 (the “Comment
        Letter”),
        the Staff of the U.S. Securities and Exchange Commission (the “Staff”)
        provided certain comments on the annual report on Form 20-F for the fiscal
        year
        ended December 31, 2004, as filed on June 30, 2005 by Natuzzi S.p.A.
        (“Natuzzi”
        or the “Group”).
        In
        accordance with the Staff’s request, Natuzzi is submitting its responses in this
        letter via EDGAR as correspondence.

      For
        ease of reference, the text of each of the Staff’s comments is set forth in full
        in this letter in italics with the response immediately following each
        italicized comment.

                  Natuzzi
                    SpA - Via Iazzitiello 47,

                  70029
                    Santeramo in Colle (BA)

                  Italy

                  1/10

                  Natuzzi
                    SpA is directed and coordinated by

                  Invest
                    2003 Srl

        Mr.
          Rufus Decker, Accounting Branch Chief

        Page
          2 of 10

      FORM
        20-F FOR THE YEAR ENDED DECEMBER 31, 2004

      General

      1.
Where
        a comment below requests additional disclosures or other revisions to be
        made,
        please show us in your supplemental response what the revisions will look
        like.
        Some of our comments refer to US GAAP literature. If your accounting under
        Italian GAAP differs from your accounting under US GAAP, please also show
        us the
        additional disclosures that will be included in your US GAAP reconciliation
        footnote. These revisions should be included in your future
        filings.

      Natuzzi
        notes the instructions regarding future filings and confirms that it will
        include disclosure in future annual reports on Form 20-F as appropriate to
        comply with the Staff’s comments. Where revisions or additional disclosures are
        required in response to the Staff’s comments, Natuzzi has shown in the response
        to the comment what the revisions or additional disclosures would look like
        if
        applied to the relevant periods. Our proposed disclosures set forth in this
        letter are subject to change based on the facts and circumstances at the
        time we
        make future filings.

      Contractual
        Obligations and Commitments, page 32

      2.
Please
        revise your table of contractual obligations to include the
        following:

              ·

                Estimated
                  interest payments on your
                  debt;

              ·

                Estimated
                  payments under interest rate swap agreements;
                  and

              ·

                Planned
                  funding of pension and other postretirement benefit
                  obligations.

        Because
          the table is aimed at increasing transparency of cash flow, we believe
          these
          payments should be included in the table. Please also disclose any assumptions
          you made to derive these amounts.

                  Natuzzi
                    SpA - Via Iazzitiello 47,

                  70029
                    Santeramo in Colle (BA)

                  Italy

                  2/10

                  Natuzzi
                    SpA is directed and coordinated by

                   Invest
                    2003 Srl

        Mr.
          Rufus Decker, Accounting Branch Chief

        Page
          3
          of 10

              o

                Natuzzi
                  respectfully submits that it did not include estimated interest
                  payments
                  in the table of contractual obligations because the amounts of
                  such
                  interest payments were not material to Natuzzi’s cash flows. Nevertheless,
                  Natuzzi supplementally confirms to the Staff that the revised disclosure
                  in footnote 1 to the table below would have been accurate as of
                  December
                  31, 2004, and that it will disclose the amounts of estimated interest
                  payments, if such amounts are applicable and can be reasonably
                  estimated,
                  in the table of contractual obligations in future annual reports
                  on Form
                  20-F beginning with its Annual Report on Form 20-F for the fiscal
                  year
                  ending December 31, 2005 (if then applicable).

                  Payments
                    Due by Period (in euro thousands)

                  Contractual
                    Obligations

                  Total

                  Less
                    than

                  1
                    year

                  1-3
                    years

                  4-5
                    years

                  After
                    5

                  years

                  Long-Term
                    Debt(1)

                  5,569

                  571

                  3,221

                  410

                  1,367

      (1)
        Amounts presented exclude the related interest expense that will be paid
        when
        due. The amount of interest due on the total amount of long-term debt is
€ 555
        thousands; the amount of interest due in less than one year is € 133 thousands;
        the amount of interest due in 1-3 years is € 248 thousands; the amount of
        interest due in 4-5 years is € 79 thousands; and the amount due after 5 years is
€ 95 thousands. Interests due on debt are calculated using fixed rates
        contractually agreed with the lenders. Please see Note 16 to the Consolidated
        Financial Statements included in this annual report for more information
        on the
        Group’s long-term debt.

              o

                Natuzzi
                  supplementally informs the Staff that it did not enter into interest
                  rate
                  swap agreements.

              o

                Natuzzi
                  supplementally informs the Staff that it has no planned funding
                  of pension
                  and other postretirement benefit obligations.

        Item
          15. Controls and Procedures, page 65

                  Natuzzi
                    SpA - Via Iazzitiello 47,

                  70029
                    Santeramo in Colle (BA)

                  Italy

                  3/10

                  Natuzzi
                    SpA is directed and coordinated by

                  Invest
                    2003 Srl

        Mr.
          Rufus Decker, Accounting Branch Chief

        Page
          4
          of 10

      3.
We
        note your disclosure that “the Chief Executive Officer and Chief Financial
        Officer concluded that the disclosure controls and procedures as of December
        31,
        2004 were effective to provide reasonable assurance that information required
        to
        be disclosed in the reports the Company files and submits under the Exchange
        Act
        is recorded, processed, summarized and reported as and when required.” Revise to
        clarify, if true, that your officers concluded that your disclosure controls
        and
        procedures are also effective to ensure that information required to be
        disclosed in the reports you file or submit under the Exchange Act is
        accumulated and communicated to your management, including your chief executive
        officer and chief financial officer, to allow timely decisions regarding
        required disclosure. See Exchange Act Rules 13(a)-15(e) and
        15(d)-15(e).

      Natuzzi
        respectfully maintains that the wording of its disclosure under Item 15 is
        substantively identical to the wording of Rule 13(a)-15(e) and that no change
        to
        the disclosure is necessary to comply with the requirements of Item
        15.

      Nevertheless,
        Natuzzi supplementally confirms to the Staff that the language below would
        accurately describe Natuzzi’s response to Item 15 as of December 31, 2004 and
        will be included (if then true) in its annual report on Form 20-F for the
        year
        ending December 31, 2005:

      Based
        upon the Company’s evaluation, the Chief Executive Officer and Chief Financial
        Officer concluded that the Company’s disclosure controls and procedures as of
        December 31, 2004 were effective to provide reasonable assurance that (i)
        information required to be disclosed in the reports the Company files and
        submits under the Exchange Act is recorded, processed, summarized and reported
        as and when required and (ii) that information required to be disclosed in
        the
        reports the Company files or submits under the Exchange Act is accumulated
        and
        communicated to the Company’s management, including the Chief Executive Officer
        and Chief Financial Officer, to allow timely decisions regarding required
        disclosure.

      Financial
        Statements

      Note
        3. Summary of Significant Accounting Policies

                  Natuzzi
                    SpA - Via Iazzitiello 47,

                  70029
                    Santeramo in Colle (BA)

                  Italy

                  4/10

                  Natuzzi
                    SpA is directed and coordinated by

                  Invest
                    2003 Srl

        Mr.
          Rufus Decker, Accounting Branch Chief

        Page
          5
          of 10

      m).
        Government Grants, page F-14

      4.
You
        state that capital grants are recognized in the consolidated statement of
        earnings as revenue based on a systematic basis over the useful life of the
        related asset. Please disclose the amount of capital grant income recorded
        in
        revenue for each period presented and help us understand why your presentation
        of these amounts as revenue is not discussed in Note 27.

      Under
        Italian GAAP, grants in the form of capital contributions are recognized
        as “net
        sales” in the statements of earnings over the useful life of the related asset.
        For the years ended December 31, 2004, 2003 and 2002, Natuzzi reported as
        net
        sales amortization of government grants of €864 thousand, €868 thousand, and
€784 thousand, respectively.

      Natuzzi
        supplementally confirms to the Staff that in its future annual reports on
        Form
        20-F, beginning with its annual report on Form 20-F for the year ending December
        31, 2005, it will separately disclose Italian GAAP revenues derived from
        government grants. Further, Natuzzi supplemental informs the Staff that the
        following description relating to government grants, drafted to be part of
        note
        27 to the consolidated financial statements would have been accurate as of
        December 31, 2004, and that it will include a similar discussion (if then
        applicable) in its future annual reports on Form 20-F beginning with its
        annual
        report for the fiscal year ending December 31, 2005:

                  Under
                    Italian GAAP until December 31, 2000 government grants related
                    to capital
                    expenditures were recorded, net of tax, within reserves in shareholders'
                    equity (see note 3 (m)).  Subsequent to that date such
                    grants have
                    been recorded as deferred income and recognized in the statement
                    of
                    earnings as revenue on a systematic basis over the useful life
                    of the
                    asset.

                  Under
                    US GAAP, such grants would be classified either as a reduction
                    of the cost
                    of the related fixed asset or as a deferred credit and amortized
                    over the
                    estimated useful lives of the assets.  The amortization
                    would be
                    treated as a reduction of depreciation expense and classified
                    in the
                    statement of earnings according to the nature of the asset to
                    which the
                    grant relates.

                  Natuzzi
                    SpA - Via Iazzitiello 47,

                  70029
                    Santeramo in Colle (BA)

                  Italy

                  5/10

                  Natuzzi
                    SpA is directed and coordinated by

                  Invest
                    2003 Srl

        Mr.
          Rufus Decker, Accounting Branch Chief

        Page
          6 of 10

                  The
                    adjustments to net income represent the annual amortization of
                    the capital
                    grants based on the estimated useful life of the related fixed
                    assets. The
                    adjustments to shareholders' equity are to reverse the amounts
                    of capital
                    grants credited directly to equity for Italian GAAP purposes,
                    net of the
                    amounts of amortization of such grants for US GAAP purposes.
                    In 1995 and
                    1997, the Group received certain grants relating to fixed assets
                    acquired
                    between 1989 and 1997 with various useful lives. For US GAAP
                    purposes, the
                    Group is amortizing such grants over the remaining useful lives
                    of the
                    assets to which the grants relate.

                  Grants
                    recognized as revenues under Italian GAAP of € 864 thousand, € 868
                    thousand and € 784 thousand for the years ended December 31, 2004, 2003
                    and 2002 respectively would be reclassified as reductions to
                    depreciation
                    expense and recorded in cost of goods sold under US GAAP.

      o).
        Net Sales, Page F-15

      5.
You
        state that revenues are recorded net of returns, warranties and discounts.
        Please disclose the amount of warranty costs recorded for each period presented
        and help us understand why your presentation of these amounts as a reduction
        of
        revenues is not discussed in Note 27.

      Natuzzi
        notes that the term “warranties” used in the description of the accounting
        principle relating to net sales in note 3(o) of the 2004 20-F refers to amounts
        refunded to customers relating to products with defects or to produ