SecProbe.io

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The Estee Lauder Companies Inc.
767 Fifth Avenue
New York, NY 10153
212.572.4200
                                                                       ESTEE
                                                                       LAUDER
                                                                       COMPANIES

November 19, 2004

Mr. Rufus Decker
Accounting Branch Chief
United States Securities and Exchange Commission
450 Fifth Street, N.W., Mail Stop 0510
Washington, D.C. 20549-0510

RE:      The Estee Lauder Companies Inc.
         Form 10-K for the fiscal year ended June 30, 2004
         File No. 1-14962

Dear Mr. Decker:

This letter sets forth the responses of The Estee Lauder Companies Inc. (the
"Company" or "we" or "our") to the comments of the staff of the U.S. Securities
and Exchange Commission (the "Commission") contained in your letter dated
November 1, 2004. The Company's responses set forth below correspond to the
comments as numbered in the staff's letter.

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. With the exception of the comments below
         that specifically request an amendment, all other revisions may be
         included in your future filings.

Company Response:
-----------------

         We note the instructions regarding future filings. 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. We also
         note that we filed an amendment to our Annual Report on Form 10-K for
         the fiscal year ended June 30, 2004 on November 5, 2004 to respond to
         comment 23 of the staff's letter.

                                  Page 1 of 18
<PAGE>

Item 7.  Management's Discussion and Analysis of Financial Condition and Results
--------------------------------------------------------------------------------
of Operations
-------------
Critical Accounting Policies and Estimates, page 17
-----------------------------------------------------------------

2.       Please expand your discussion of critical accounting policies to
         address the following:
         o     Types of assumptions underlying the most significant and
               subjective estimates;
         o     Any known trends, demands, commitments, events or uncertainties
               that are reasonably likely to occur and materially affect the
               methodology or the assumptions described;
         o     A quantitative discussion of changes in overall financial
               performance if you were to assume that the accounting estimate
               were changed, either by using reasonably possible near-term
               changes in the most material assumptions underlying the
               accounting estimate or by using the reasonably possible range of
               the accounting estimate.
         o     A quantitative and qualitative discussion of any material changes
               made to the accounting estimate in the past three years, the
               reasons for the changes, and the effect on your overall financial
               performance;
         Refer to SEC Releases 33-8098 and 33-8350.

Company Response:
-----------------

         We noted the reference to the Commission's Proposed Rule, SEC Release
         33-8098, and the Commission's Interpretation, SEC Release 33-8350. We
         disclosed in our Annual Report on Form 10-K for the fiscal year ended
         June 30, 2004, that our critical accounting policies are revenue
         recognition, concentration of credit risk, inventory, pension and other
         postretirement benefit costs, goodwill and other intangible assets,
         income taxes and derivatives. We also disclosed that those critical
         accounting policies include three subjective critical estimates (i.e.,
         sales return accrual, allowance for doubtful accounts and income tax
         reserves). We will disclose additional information regarding these
         accounting policies and subjective critical estimates in our Annual
         Report on Form 10-K for the fiscal year ending June 30, 2005. The
         following is an example of how we expect to provide these disclosures
         in future filings:

              Revenue Recognition
              Revenues from merchandise sales are recognized upon transfer of
              ownership, including passage of title to the customer and transfer
              of the risk of loss related to those goods. In the Americas
              region, sales are recognized at the time the product is shipped to
              the customer and, in the Europe, Middle East & Africa and Asia/
              Pacific regions, sales are recognized based upon the customer's
              receipt. In certain circumstances, transfer of title takes place
              at the point of sale (e.g., at our retail stores).

                                  Page 2 of 18
<PAGE>

              Sales are reported on a net sales basis, which is computed by
              deducting from gross sales the amount of actual product returns
              received, discounts, incentive arrangements with retailers and an
              amount established for anticipated product returns. The Company's
              practice is to accept product returns from retailers only if
              properly requested, authorized and approved. In accepting returns,
              we typically provide a credit to the retailer against accounts
              receivable from that retailer. As a percentage of gross sales,
              returns were X%, 4.6% and 5.1% in fiscal 2005, 2004 and 2003,
              respectively.

              Our sales return accrual is a subjective critical estimate that
              has a direct impact on reported net sales. This accrual is
              calculated based on a history of actual returns by region,
              estimated future returns and information provided by authorized
              retailers regarding their inventory levels. Consideration of these
              factors results in an accrual for anticipated sales returns that
              reflects increases or decreases related to seasonal fluctuations.
              Experience has shown a correlation between retailer inventory
              levels and sales returns in the subsequent period, as well as a
              consistent pattern of returns due to the cyclical nature of our
              business. In addition, as necessary, specific accruals may be
              established for future known or anticipated events. The types of
              known or anticipated events that we have considered, and will
              continue to consider, include, but are not limited to, solvency of
              our customers, store closings by retailers, the economic retail
              environment and our decision to continue or support new and
              existing products.

              Management of the Company has discussed the selection of
              significant accounting policies and the effect of estimates with
              the Audit Committee of the Company's Board of Directors.

         We will expand our discussions, in our Annual Report on Form 10-K for
         the fiscal year ending June 30, 2005, to note any:

              o     Significant known trends, demands, commitments, events or
                    uncertainties that were reasonably likely to occur and
                    materially affect the methodology or assumptions used for
                    our critical accounting policy estimates; and

              o     Specific accruals which may be necessary for future known or
                    anticipated events.

                                  Page 3 of 18
<PAGE>

         We will provide in our Annual Report on Form 10-K for the fiscal year
         ending June 30, 2005, a quantitative discussion of changes in overall
         financial performance if we were to assume that our subjective critical
         estimates were changed, (i.e., our sales return accrual, allowance for
         doubtful accounts and income tax reserves) by using a reasonably
         possible range of estimates or factors to derive these balances, as
         follows:

              While we believe that the estimates that we have made are proper
              and the related results of operations for the period are presented
              fairly in all material respects, other assumptions could
              reasonably be justified that would change the amount of reported
              net sales, cost of sales, selling, general and administrative
              expenses or our provision for income taxes as they relate to the
              provisions for anticipated sales returns, allowance for doubtful
              accounts and income taxes. Had these estimates been changed by X%
              in either direction, our reported net sales would have increased
              or decreased by approximately $XX million, the related cost of
              sales would have changed by approximately $XX million, selling,
              general and administrative expenses would have changed by
              approximately $XX million and the provision for income taxes would
              have increased or decreased by approximately $XX million. Had
              these changes occurred simultaneously, the impact of such changes
              on operating income and net earnings per diluted common share
              would have increased, or decreased, by approximately $XX million
              or $XX per diluted common share.

         We will expand our discussions, in our Annual Report on Form 10-K for
         the fiscal year ending June 30, 2005, to provide additional disclosure
         as follows:

              During the three-year period ended June 30, 2005, there have not
              been material changes in the assumptions underlying these critical
              accounting policies, nor to the related significant estimates,
              since the results of our business underlying these assumptions
              have not differed significantly from our expectations.

         Please note that if there are significant changes in our assumptions or
         the results underlying those assumptions, we will then provide the
         appropriate disclosure.

Reconciliations of Financial Results, page 21
---------------------------------------------

3.       Your presentation of condensed statements of earnings described as
         "Non-GAAP Results" gives too much prominence to amounts not calculated
         and presented in accordance with GAAP. Given the guidance of Item 10(e)
         (1)(i)(A) of Regulation S-K, please remove the non-GAAP statements of
         earnings. Naturally, you may present specific non-GAAP measures, as
         long as the requirements in Item 10(e) of Regulation S-K have been met.

                                  Page 4 of 18
<PAGE>

Company Response:
-----------------

         We will exclude the fiscal 2003 table from our Annual Report on Form
         10-K for the fiscal year ending June 30, 2005. In order to provide
         necessary clarification, we will modify the paragraphs presently under
         the heading "Reconciliation of Financial Results" and move that
         discussion under the subheading "Operating Expenses" in order to
         reconcile the GAAP and non-GAAP results as follows:

              Our fiscal 2003 results, as reported in conformity with U.S.
              generally accepted accounting principles ("GAAP"), include an
              adjustment for a special pre-tax charge of $22.0 million, or $13.5
              million after tax, equal to $.06 per diluted common share, in
              connection with the proposed settlement of a class action lawsuit
              brought against us and a number of other defendants. The amount of
              the charge in this case is significantly larger than similar
              charges we have incurred individually or in the aggregate for
              legal proceedings in any prior year and we do not expect to take a
              charge of a similar magnitude for a single matter like it in the
              near future. In our discussions of "Operating Expenses" and
              "Operating Results" we include the results as reported and the
              non-GAAP results. We have presented the non-GAAP results because
              of the special nature of the charge, which affects comparability
              from period to period. We believe that such measures provide
              investors with a view of our ongoing business trends and results
              of continuing operations. This is consistent with the approach
              used by management in its evaluation and monitoring of such trends
              and results and provides investors with a base for evaluating
              future periods. There were no events or transactions subsequent to
              fiscal 2003 for which we believe such a presentation would be
              relevant.

              In fiscal 2003, operating expenses and operating income in
              accordance with GAAP were $3,267.9 million or 64.1% of net sales
              and $503.7 million or 9.9% of net sales, respectively. Before the
              charge (non-GAAP results) operating expenses would have been
              $3,245.9 million or 63.7% of net sales and operating income would
              have been $525.7 million or 10.3% of net sales.

              While we consider the non-GAAP financial measures useful in
              analyzing our results, it is not intended to replace, or act as a
              substitute for, any presentation included in the consolidated
              financial statements prepared in conformity with GAAP.

4.       You have presented the 2003 reconciliation as the special pre-tax
         charge of $22.0 million in connection with the proposed settlement of a
         class action lawsuit is significantly larger than similar charges
         incurred individually or in the aggregate. It appears that costs of a
         similar nature would have been incurred within the prior two years or
         are likely to recur within the subsequent two years. Please tell us how
         you considered the requirements in Item l0(e)(l)(ii)(B) of Regulation
         S-K.

                                  Page 5 of 18
<PAGE>

   Company Response:
   -----------------

         In providing this disclosure we did consider the requirements of Item
         10(e)(1)(ii)(B) of Regulation S-K and other guidance regarding the use
         of non-GAAP financial measures.

         We used the non-GAAP measure in our MD&A to explain the impact that the
         charge had on our operating expenses, operating margin and diluted net
         earnings per common share for our fiscal year ended June 30, 2003 to
         help investors more easily view and compare our ongoing business trends
         and results of continuing operations.

         The legal matter underlying the charge was a unique class action
         lawsuit. We were never involved in any cases like it before we took the
         charge and, given our long history and the way we operate our business,
         did not believe it was reasonably likely that there would be a charge
         of this nature or of a similar magnitude for a single matter like it
         within the next two years. The reference to "similar charges" was only
         meant to recognize that we have taken charges relating to legal matters
         in the past, but no charge of an