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                             [Publicis Groupe Logo]

               Jean-Michel Etienne, Group Chief Financial Officer
                              Publicis Groupe S.A.
                         133 avenue des Champs-Elysees
                              75008 Paris, France

September 15, 2005

Securities and Exchange Commission
Mail Stop 3561
CF/AD11
100 F St. NE
Washington, DC 20549-3561
USA

Re:   Publicis Groupe S.A.
      Response to Staff Comments

Dear Mr. Spirgel,

In my capacity as Chief Financial Officer of Publicis Groupe S.A. (the
"Company"), Maurice Levy, CEO and Chairman of the Management Board of the
Company, has asked me to respond to your letter dated August 23, 2005, regarding
the Annual Report on Form 20-F for the year ended December 31, 2004, filed by
the Company on June 24, 2005 (the "Form 20-F").

We have carefully reviewed the Staff's comments and our responses are set out
below. The titles and paragraph numbers below correspond to those contained in
your letter. For convenience, we have repeated the Staff's comments under each
number in bold and have followed each comment with our response.

FORM 20-F
FINANCIAL STATEMENTS
1.1. CONSOLIDATION PRINCIPLES AND POLICIES, PAGE F-6

1. YOUR US GAAP CONSOLIDATION POLICIES ARE UNCLEAR, PLEASE CLARIFY IN FUTURE
FILINGS AND ADVISE US IN DETAIL. YOU SHOULD SPECIFICALLY ADDRESS IN YOUR
RESPONSE THOSE SUBSIDIARIES AND INVESTEES IN WHICH YOU DO NOT HAVE A CONTROLLING
FINANCIAL INTEREST BY WAY OF A MAJORITY VOTING INTEREST. CITE FOR US THE US
ACCOUNTING LITERATURE THAT IS YOUR BASIS FOR YOUR POLICIES.

                                                                               1

<PAGE>

The consolidation policies described in Note 1.1 to the consolidated financial
statements (page F-6) are compliant with French GAAP which specifically requires
that entities be consolidated when effective control is demonstrated but does
not require the consolidation of non significant entities.

For US GAAP reporting, the Company applies the provisions of FIN 46 and SFAS 94
for the determination of consolidated companies and those of APB 18 for
accounting for investments in affiliates.

Differences between French GAAP and US GAAP are not reported in the note of
reconciliation since they do not have a significant impact on reconciled net
income and reconciled net equity, or on the presentation of condensed balance
sheets and income statements on pages F-56 and F-58, respectively (see below for
quantification of the differences).

The subsidiaries and investees which are fully consolidated and in which we do
not have a controlling financial interest by way of a majority voting interest
are listed below:

     o     Le Monde Publicite (49%)
     o     Espace Liberation (49%)
     o     Bromley Communications (49%)
     o     Regie 1 (50%)
     o     JCD Netherlands (50%)

While reporting the above entities under the equity method under US GAAP would
not have impacted reconciled net income or reconciled net equity, the table
below discloses the cumulative reduction (in %) on certain related lines of the
consolidated financial statements:

     ----------------------------------------------
                              Operating   Total
     Impact %      Revenue     income     Assets
     ----------------------------------------------
     Year 2002      2.76%      3.05%      1.76%
     ----------------------------------------------
     Year 2003      1.89%      1.84%      1.51%
     ----------------------------------------------
     Year 2004      2.01%      2.70%      1.57%
     ----------------------------------------------

It should be noted that in May 2005 Publicis Groupe announced that it had signed
an agreement with JCDecaux SA, which included the planned sale to JCDecaux of
the 50% shareholding held by Publicis Groupe in JCDecaux Netherlands BV.

In addition, as disclosed in our French GAAP accounting policies, one entity in
which we have a controlling financial interest by way of a majority voting
interest (80%) is not consolidated, with an impact of less than 0.01% of 2002,
2003 and 2004 consolidated revenue, operating income, net income and total
assets.

Other non significant entities with a voting interest of less than 50% are
carried at cost and not accounted for under the equity method; this difference
represents a cumulative impact of 0.19% of 2004 consolidated net income
(respectively, 0.41% in 2003 and 0.33% in 2002).

                                                                               2

<PAGE>

In conclusion, Publicis Groupe considers the differences between French GAAP and
US GAAP to be insignificant.

In future filings, the Company will prepare its consolidated financial
statements under IFRS and will therefore perform a review of the description of
its accounting policies, including consolidation policies, to comply with this
new body of accounting principles. The Company will describe any significant
accounting differences between IFRS and US GAAP as part of the note of
reconciliation.

31.  SUMMARY OF DIFFERENCES BETWEEN GENERALLY ACCEPTED ACCOUNTING PRINCIPLES IN
     FRANCE AND THE UNITED STATES, PAGE F-47

2.   WE NOTE UNDER FRENCH GAAP YOU USE THE  PERCENTAGE OF  COMPLETION  METHOD TO
     RECOGNIZE REVENUE FOR SERVICES RENDERED. TELL US IF YOU USE THIS POLICY FOR
     US  GAAP  REPORTING  PURPOSES,  AND IF SO,  DESCRIBE  FOR US THE  TYPES  OF
     SERVICES FOR WHICH THE  PERCENTAGE OF COMPLETION  METHOD IS USED.  ALSO, IF
     APPLICABLE,  TELL US HOW  MUCH  US  GAAP  REVENUE  YOU  RECOGNIZED  IN EACH
     REPORTING  PERIOD  USING THIS  METHOD.  YOU SHOULD ALSO SUPPORT YOUR USE OF
     PERCENTAGE OF COMPLETION  ACCOUNTING UNDER US GAAP.  EXPLAIN YOUR BASIS FOR
     USING AN INPUT  MEASURE  FOR  REVENUE  RECOGNITION  RATHER  THAN AN  OUTPUT
     MEASURE.  COMPARE FOR US THE IMPACT OF USING THE  PERCENTAGE  OF COMPLETION
     METHOD WITH AN OUTPUT MEASURING METHODOLOGY AND STRAIGHT-LINE  METHODOLOGY.
     PLEASE REFER US TO US GAAP ACCOUNTING  LITERATURE THAT SUPPORTS YOUR USE OF
     THIS POLICY.

The Company's policy for revenue recognition distinguishes between commission
based customer arrangements and other arrangements as follows:

o    Commission based customer arrangements are recognized when the services are
     rendered, specifically when the publication or broadcast for advertising
     creation and media space buying services occurs.

o    For other arrangements, revenue is recognized when the service is
     performed.

     Other arrangements include:

          o    Traditional advertising arrangements

               -    Fixed fee arrangements are recognized on a straight-line
                    basis as such advertising services are performed.

               -    Arrangements based on fee per hour or per day are recognized
                    based on work performed.

               -    Production arrangements (films, video, prints...) are
                    recognized when the service is performed; such performance
                    is measured based on time spent as compared to time budgeted
                    and is corroborated by the acceptance of the contractual
                    phases by the client. If no phases are defined, revenue is
                    deferred and recognized when the client accepts the product.
                    In any case, it should be noted that the production cycle is
                    very short (generally a few weeks).

                                                                               3
<PAGE>

               -    Incentive amounts included in some arrangements are
                    recognized only when (i) performance measured against
                    qualitative objectives determined by the client and client
                    acceptance are determined; (ii) quantitative objectives are
                    achieved and can be substantiated and the bonus is no longer
                    contingent or refundable; and (iii) collectibility is
                    assured.

          o    Specialized agencies and marketing services agencies perform
               various marketing and communications services. Those services are
               rendered based on short-term project arrangements on a fee basis.
               Revenue is only recognized when services contractually required
               have been rendered. If incentive amounts are included, they are
               recognized in a manner similar to traditional advertising
               contracts as described in our response to comment 2 above.

The reference made to percentage of completion method in the "Revenue" section
of Note 1.2 covers the production arrangements as described above. The Company
believes that it can reasonably estimate the extent of progress of a production
contract by comparing hours incurred to total budget hours and use it as
performance indicator. Such indicator, in conjunction with achievement of
contractual steps accepted by the client, is used to determine the proportion of
the performance achieved and, consequently, revenue earned. As indicated above,
no revenue is recognized if no contractual step has been accepted by the client.

The Company will revise in future filings the description of revenue recognition
of its production services to describe the criteria used to measure proportional
performance.

SEGMENT INFORMATION, PAGE F-78

3.   REFER TO THE PARAGRAPH BRIDGING PAGES F-39 AND F-40. FOR US GAAP PURPOSES,
     TELL US WHY IT IS NO LONGER MEANINGFUL TO PRESENT TWO DISTINCT BUSINESS
     SEGMENTS. EXPLAIN HOW YOU APPLIED THE GUIDANCE OF SFAS 131. IDENTIFY YOUR
     CHIEF OPERATING DECISION MAKER. IDENTIFY YOUR SEGMENT MANAGERS AND GIVE US
     EXAMPLE COPIES OF THE REPORTS USED BY YOUR CHIEF OPERATING DECISION MAKER
     TO ALLOCATE RESOURCES AND TO ASSESS PERFORMANCE OF YOUR SEGMENTS. IF
     APPROPRIATE, DESCRIBE HOW YOU APPLY THE AGGREGATION CRITERIA OF SFAS 131.

In 2001 and before, the Company in its business overview presented in its 20-F
two separate operating divisions, "Communications" and "Other Activities", that
included Media sales and the operations of Drugstore Publicis restaurant; "Other
activities" represented around 6% of Groupe activities at that time. The Company
reported a single segment "Communications" in the financial statement footnotes,
as "Other Activities" were not significant.

In 2002, the Company modified its presentation in the business overview and no
longer presented "Other Activities" as an operating division as its relative
size decreased significantly after the acquisition of Bcom3 and represented
4.56% of total revenues in 2002 (3.37% in 2004).

                                                                               4
<PAGE>

For US GAAP purposes, the Company has presented one single reporting segment
since its initial registration statement.

The sentence "It is no longer meaningful to present two distinct business
segments given the scale of the Group's Communications business since its
acquisition of Bcom3" should have been deleted for 2004 financial statements
under French and US GAAP and will not be included in future filings.

PUBLICIS GROUPE SEGMENT REPORTING

DETERMINATION OF OPERATING SEGMENTS

In order to determine our operating segments, we have reviewed the business
organization of the Company and the internal reporting used by the Company's
Chief Operating Decision Maker.

The monthly internal reporting books for the years 2003 and 2004 will be
submitted separately as supplemental, confidential materials.

The Chief Operating Decision Maker of Publicis Groupe is the Management Board.
Its function is to define the strategy of the Company, monitor its
implementation and oversee the management of its operations. In that respect,
the Chief Operating Decision Maker is responsible for the allocation of
resources and review of the operating results of the Groupe entities.

The members of the Management Board are the following:

     -    Maurice Levy: Chairman of the Management Board.

     -    Jack Klues:  Director and Chief Executive Officer of Starcom MediaVest
          Group in 2004 and Chief  Executive  Officer of Publicis  Groupe  Media
          since January 1, 2005.

     -    Kevin Roberts: Director and President of Saatchi & Saatchi.

     -    Bertrand Siguier: Director.

     -    Claudine Bienaime: Director and General Secretary.

The monthly internal reporting is organized in eight separately identified
Brands:

     o    Publicis

     o    Saatchi & Saatchi

     o    Leo Burnett

     o    Fallon

     o    SAMS (Specialized Agencies and Marketing Services)

     o    Publicis Groupe Media (PGM)

     o    Medias & Regies

     o    Other and Corporate

                                                                               5

<PAGE>

Publicis, Saatchi & Saatchi, Leo Burnett and Fallon are Brands which primarily
provide traditional advertising services together with SAMS services that are
provided both by traditional advertising network agencies and specialized
agencies. These Brands constitute our Advertising segment.

Publicis Groupe Media is composed of two Brands (Starcom MediaVest Group and
ZenithOptimedia Group) that provide media planning and buying services. Medias &
Regies sells advertising space to advertising and media buying firms on behalf
of media companies. Publicis Groupe Media and Medias & Regies constitute our
Media segment.

Each of these Brands is headed by a manager whose responsibility is primarily to
manage operations and financial performance but is not in charge of resources
allocation and global strategy.

We reviewed each of these Brands in order to determine if they are operating
segments as defined in SFAS 131.

An operating segment is defined by SFAS 131 as a component of an enterprise:

     a)   that engages in business activities from which it may earn revenues
          and incur expenses,

     b)   whose operating results are regularly reviewed by the enterprise's
          Chief Operating Decision Maker to make decisions about resources to be
          allocated to the segment and assess its performance, and

     c)   for which discrete financial information is available.

All eight Brands meet the criteria a) and c). However, allocation of resources
made by Publicis Groupe's Chief Operating Decision Maker is not based on this
organization but based on global allocation between advertising and media
operations to improve client services and geographical development and achieve
our global strategy. In other words, the Company uses an account (or
client)-centric approach whereby many advertising accounts cut across the
identified Brands. Accordingly, the Company and its Chief Operating Decision
Maker must allocate resources at the global advertising level as opposed to the
Brand level. This concept is explained in greater detail in the following
paragraphs:

o    Our strategy is a global  strategy and is not based on Brand  organization.
     Our  strategy  is to increase  on a  country-by-country  basis the scope of
     services we provide to clients,  particularly  services for which demand is
     growing rapidly. We also intend to continue pursuing our strategy of making
     selective acquisitions to round out our geographical and service offerings.
     We want to make  selective  acquisitions  to achieve  critical  mass in key
     markets and take  opportunities  for growth in emerging  economies  (China,
     India, Russia).

                                                                               6

<PAGE>

o    For a newly acquired company,  the Chief Operating Decision Maker allocates
     the various  agencies to one of the Company's Brands using criteria such as
     professional  skills,  chemistry and potential conflict of interes