SecProbe.io

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Mail Stop 0407

      							November 15, 2005

Via U.S. Mail and Fax
Mrs. Elizabeth J. Huebner
Senior Vice President and Chief Financial Officer
Getty Images, Inc.
6312 S. Fiddlers Green Circle
Suite 360E
Greenwood Village, Colorado 80111

	RE:	Getty Images, Inc.
		Form 10-K for the fiscal year ended December 31, 2004
		File No. 000-23747

Dear Mrs. Huebner:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your documents in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

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

Form 10-K for the fiscal year ended December 31, 2004

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations (MD&A)

Revenue, page 13

1. We note that revenues increased from fiscal year 2003 to 2004
due
to certain factors, including reduced levels of discounting for
certain uses of rights-managed imagery.  Please tell us more
details
of this discounting and your related accounting policy.

Income tax Expense, page 14

2. We note that you reversed your valuation allowance in 2003.
Please provide us with more specific details of this reversal and
the
factors used in your determination that this reversal was
appropriate.

Property and Equipment, page 21

3. Tell us how you determine impairment for your imagery.

Item 8. Consolidated Financial Statements and Supplementary Data

Consolidated Statements of Income, page F-4

4. If the captions "cost of sales" and "gross profit" exclude
depreciation and amortization for property and equipment directly
attributed to the generation of revenue, we believe that this
presentation inappropriately reports a figure of income before
depreciation and amortization.  As required by SAB 11:B, revise
your
presentation to either reclassify the applicable depreciation to
"cost of sales" or remove the caption "gross margin" and indicate
the
amount of applicable depreciation that is excluded from "cost of
sales."

Form 10-Q for the quarterly period ended September 30, 2005

Note .2 Acquisitions of Business, page 11

5. We note significant goodwill was recorded relating to the
Digital
Vision and Photonica acquisitions.  Please tell us the details of
the
intangibles recorded relating to these acquisitions.  In addition
please tell us your consideration of assigning any value to other
intangibles, including image content and relationships with
contributors.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please file your response on EDGAR.
Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes 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 are 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 writing, a statement from the company acknowledging that:

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

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Michael Henderson, Staff Accountant, at
(202)
551-3364 or Kyle Moffatt, Accountant Branch Chief, at (202) 551-
3384
if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3810 with any
other questions.

								Sincerely,

								Larry Spirgel
								Assistant Director
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Mrs. Elizabeth J. Huebner
Getty Images, Inc.
November 15, 2005
Page 4

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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