SecProbe.io

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 July 7, 2025

Andrew Emerson
Chief Financial Officer and Treasurer
IDEXX Laboratories Inc.
One IDEXX Drive
Westbrook, Maine 04092

 Re: IDEXX Laboratories Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Filed February 21, 2025
 File No. 000-19271
Dear Andrew Emerson:

 We have completed our review of your filing. We remind you that the
company and
its management are responsible for the accuracy and adequacy of their
disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of Corporation
Finance
 Office of Life Sciences
</TEXT>
</DOCUMENT>

CORRESP
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 Document by EDGAR June 2, 2025 Frank Wyman Division of Corporation Finance Office of Life Sciences United States Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re:    IDEXX Laboratories, Inc. Form 10-K for the Fiscal Year Ended December 31, 2024 Filed February 21, 2025 File No. 000-19271 Dear Mr. Wyman, IDEXX Laboratories, Inc. (“IDEXX” or the “Company”) is submitting this letter in response to the written comment contained in the letter (the “Comment Letter”) of the staff of the Division of Corporation Finance – Office of Life Sciences (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated May 21, 2025, relating to the above-referenced filing. To facilitate the Staff’s review, the text of the Staff’s comment is repeated below prior to the Company’s response. Form 10-K for the Fiscal Year Ended December 31, 2024 Notes to Consolidated Financial Statements Note 17. Segment Reporting, page F-40 1. We note your response to our prior comment. You disclose on page F-40 that foreign currency transaction gains and losses are reported within your “Other operating segment." Please explain in detail how, when you identified your operating segments, you determined foreign currency transaction gains or losses would be included in your “Other operating segment” and not in your operating segments that are reportable. As part of your response, please address the following: • You indicate in the proposed disclosure in your response that foreign currency transaction gains and losses are centrally managed by your corporate treasury function. Describe the “Other operating segment” in further detail and how foreign currency transactions gains and losses are managed. • Describe the balance(s) that foreign currency transaction gains and losses are associated with. In this regard, we note your disclosure on page F-40 that “assets are not allocated to segments for internal reporting purposes." • Tell us how the “Impact from foreign currency” contained in the proposed disclosure in your response was calculated for each reportable segment, and whether the CODM is provided with this information. IDEXX Response: The Company respectfully advises the Staff that our “Other operating segment” is the combination of our human medical diagnostic segment (“OPTI Medical”) and our out-licensing arrangements segment. Neither of these segments are considered to be reportable segments because they do not meet the qualitative or quantitative thresholds in ASC 280-10-50-10b (revenue and income from operations for each segment are less than 1% of consolidated totals). Excluded from the segment reporting provided to the CODM are foreign currency transaction gains and losses since these are financial risks rather than operational metrics. In our Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”), “Other” included (a) results from the OPTI Medical segment, (b) results from our out-licensing arrangements segment, and (c) foreign currency transaction gains and losses for the entire company. These foreign currency transaction gains and losses arise from monetary 1 assets and liabilities that are denominated in currencies other than the functional currency of the respective subsidiaries. Since assets and liabilities are not allocated to segments for internal reporting purposes and are not included in reviews performed by the CODM for the purpose of assessing segment performance and allocation of resources, the foreign currency transaction gains and losses are also not allocated to the operating segments and our systems and reporting are not structured to identify or allocate foreign currency transaction impacts at the segment level. Monetary assets and liabilities are primarily comprised of cash, accounts receivable, accounts payable and accrued expenses. The currencies in which receivables are denominated and the associated payment terms granted to the counterparties are generally determined by the Company with consideration to local business practices in the geography in which our respective operating subsidiary resides. The currencies in which liabilities are incurred and the timing of settlements of those liabilities are generally determined by mutually agreed terms with the respective counterparties. The Company’s management evaluates segment operating performance based on revenues, gross profit, and operating income before foreign transaction gains and losses because it helps management understand and evaluate the segments’ core operating results. The Company considers the financial risk of foreign currency transactions as a corporate item and our overall cash inflows and outflows are centrally managed by our corporate treasury function based on the expected timing of cash receipts and payments, planned investing and financing activities of the Company, and assessment of financial risks and mitigation efforts, in order to optimize liquidity and the use of excess cash, and to mitigate currency and other relevant risks. In future filings we will clarify our disclosure that previously appeared on page F-40 of our Form 10-K, to state that we do not allocate foreign transaction gains and losses to our operating segments. In addition, wherever we disclose “Other results of operations” such as the table on page 54 of our Form 10-K for the year ended December 31, 2024, we will clarify that this includes the results from our non-reportable segments and consolidated foreign transaction gains and losses. In the table provided within our response dated April 30, 2025, foreign currency transaction gains and losses were allocated to reportable segments in proportion to their respective foreign-sourced revenues for the relevant periods. Since assets and liabilities are not allocated to segments for internal reporting purposes and are not included in reviews performed by the CODM for purposes of assessing segment performance or allocation of resources, we chose this methodology to apportion the foreign currency transaction gains and losses in order to reconcile consolidated income from operations to the amounts we present as segment income from operations in MD&A. The CODM is not regularly provided with this information. Upon further consideration the Company will revise this proposed disclosure in future periodic filings commencing with the Form 10-Q for the period ended June 30, 2025, to reconcile total consolidated GAAP income from operations to total reportable segment operating income from operations as presented in MD&A. See below for our proposed disclosure using financial information from the years ended December 31, 2024 and 2023. The Company will also include similar disclosures in our future quarterly earnings press releases regarding the Company’s results of operations furnished on Form 8-K. 2 If you should have any further questions, please contact the undersigned at andrew-emerson@idexx.com. Sincerely, /s/ Andrew Emerson Andrew Emerson Executive Vice President, Chief Financial Officer and Treasurer cc:    Ms. Angela Connell, Office of Life Sciences, Division of Corporation Finance, U.S. Securities and Exchange Commission Ms. Sharon E. Underberg, Executive Vice President, General Counsel and Corporate Secretary 3

<DOCUMENT>
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<TEXT>
 May 21, 2025

Andrew Emerson
Chief Financial Officer and Treasurer
IDEXX Laboratories Inc.
One IDEXX Drive
Westbrook, Maine 04092

 Re: IDEXX Laboratories Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Filed February 21, 2025
 File No. 000-19271
Dear Andrew Emerson:

 We have reviewed your April 30, 2025 response to our comment letter and
have the
following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our April 24,
2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024
Notes to Consolidated Financial Statements
Note 17. Segment Reporting, page F-40

1. We note your response to our prior comment. You disclose on page F-40
that foreign
 currency transaction gains and losses are reported within your Other
operating
 segment." Please explain in detail how, when you identified your
operating segments,
 you determined foreign currency transaction gains or losses would be
included in your
 Other operating segment and not in your operating segments that
are reportable. As
 part of your response, please address the following:
 You indicate in the proposed disclosure in your response that
foreign currency
 transaction gains and losses are centrally managed by your corporate
treasury
 function. Describe the Other operating segment in further
detail and how
 foreign currency transactions gains and losses are managed.
 May 21, 2025
Page 2

 Describe the balance(s) that foreign currency transaction gains
and losses are
 associated with. In this regard, we note your disclosure on page
F-40 that assets
 are not allocated to segments for internal reporting purposes."
 Tell us how the Impact from foreign currency contained in
the proposed
 disclosure in your response was calculated for each reportable
segment, and
 whether the CODM is provided with this information.

 Please contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
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CORRESP
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 Document by EDGAR April 30, 2025 Frank Wyman Division of Corporation Finance Office of Life Sciences United States Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re:    IDEXX Laboratories, Inc. Form 10-K for the Fiscal Year Ended December 31, 2024 Filed February 21, 2025 File No. 000-19271 Dear Mr. Wyman, IDEXX Laboratories, Inc. (“IDEXX” or the “Company”) is submitting this letter in response to the written comment contained in the letter (the “Comment Letter”) of the staff of the Division of Corporation Finance – Office of Life Sciences (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated April 24, 2025, relating to the above-referenced filing. To facilitate the Staff’s review, the text of the Staff’s comment is repeated below prior to the Company’s response. Form 10-K for the Fiscal Year Ended December 31, 2024 Notes to Consolidated Financial Statements Note 17. Segment Reporting, page F-40 1. We note that in prior periods, up to and including the nine months ended September 30, 2024, you presented Income from operations as your reported measure of segment profit or loss. It appears that you changed your reported measure of segment profit or loss upon the adoption of ASU 2023-07 and now disclose gross profit for each segment in addition to revenues. In your MD&A, however, you continue to present Income from operations for each segment, which includes reported amounts of sales and marketing, general and administrative and research and development expenses. Please clarify for us whether Income from operations for each segment is reported to the CODM and the extent to which this measure is used to evaluate segment performance and allocate resources. To the extent this measure is considered by the CODM when assessing performance and allocating resources, please explain how you determined the appropriate measure(s) to report under ASC 280-10-50-28A. In this regard, at least one of the reported segment profit or loss measures shall be that which management believes is determined in accordance with the measurement principles most consistent with those used in measuring the corresponding amounts in your consolidated financial statements. IDEXX Response: The Company respectfully advises the Staff that the CODM, its president and Chief Executive Officer, evaluates the performance of operating segments based on revenues and two measures of segment profit: (1) segment gross profit and (2) segment income from operations. Segment gross profit and segment income from operations are both measures of segment profit that the CODM uses to assess segment performance and allocate resources. The CODM reviews budget and actual revenues, gross profits, and income from operations of the operating segments and decides how to allocate resources to meet our strategic priorities. Generally, the Company uses the same accounting principles in the preparation of the segment information as those used for the consolidated financial statements. However, segment income from operations does not include foreign currency transaction gains and losses. 1 We regularly assess the financial information provided to the CODM, which is refined from time-to-time to support the evolving information needs of the CODM. During the preparation of the Company’s segment disclosures in connection with our adoption of ASU 2023-07, we determined segment gross profit to be the profit measure that is measured most consistently in accordance with the measurement principles used in measuring the corresponding amounts in our consolidated financial statements, compared to segment income from operations. This determination was based on the following considerations: a. The aggregated segment gross profit for our reportable and non-reportable segments is presented on a consistent basis with how it is presented on the face of our consolidated statements of income. b. Because we do not include foreign currency transaction gains and losses in our reportable segments, segment income from operations is not presented on the same basis as consolidated income from operations on the face of our consolidated statements of income. Therefore, the Company concluded that segment gross profit is the segment measure of profit that is determined in accordance with the measurement principles most consistent with those used in measuring the corresponding amounts in the Company’s consolidated financial statements (ASC 280-10-50-28A). Additionally, we determined that we would not report segment income from operations as an additional voluntary measure upon adoption of ASU 2023-07 as is allowed under the standard (ASC 280-10-50-28A). Further, to enhance the Company’s disclosures in future periodic reports on Forms 10-Q and 10-K, beginning with the Form 10-Q for the three months ended March 31, 2025, the Company will include additional disclosure to describe and reconcile segment income from operations to consolidated income from operations, in Management’s Discussion and Analysis of Financial Condition and Results of Operations . The disclosure will be similar to the following: Non-GAAP Financial Measures Segment Income from Operations . We report segment income from operations in our discussion of the results of the operations of our segments below. Segment income from operations is a non-GAAP financial measure that adjusts for the impact of foreign currency transaction gains and losses and should be considered in addition to, and not as a replacement for, income from operations. We exclude foreign currency transaction gains and losses for each reportable segment (CAG, Water, and LPD) from segment income from operations and report the full amount of foreign currency transaction gains and losses in our Other operating segment. We believe that reporting segment income from operations provides supplemental analysis to help investors further evaluate each reportable segment’s business performance by excluding foreign currency transaction gains and losses, which are centrally managed by our corporate treasury function and which we do not consider relevant for assessing the results of each reportable segment’s operations. In addition, we believe that reporting segment income from operations provides information to investors regarding key metrics that are used by management, including our CODM, in evaluating the performance of each reportable segment. The following table presents the reconciliation from income from operations for each of our segments to the amounts we present as segment income from operations for such segments in the Results of Operations below. The Company will also include similar disclosure in our future quarterly earnings press releases regarding the Company’s results of operations furnished on Form 8-K. 2 If you should have any further questions, please contact the undersigned at andrew-emerson@idexx.com. Sincerely, /s/ Andrew Emerson Andrew Emerson Executive Vice President, Chief Financial Officer and Treasurer cc:    Ms. Angela Connell, Office of Life Sciences, Division of Corporation Finance, U.S. Securities and Exchange Commission Ms. Sharon E. Underberg, Executive Vice President, General Counsel and Corporate Secretary 3

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<TEXT>
 April 24, 2025

Andrew Emerson
Chief Financial Officer and Treasurer
IDEXX Laboratories Inc.
One IDEXX Drive
Westbrook, Maine 04092

 Re: IDEXX Laboratories Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Filed February 21, 2025
 File No. 000-19271
Dear Andrew Emerson:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2024
Notes to Consolidated Financial Statements
Note 17. Segment Reporting, page F-40

1. We note that in prior periods, up to and including the nine months ended
September
 30, 2024, you presented Income from operations as your reported measure
of segment
 profit or loss. It appears that you changed your reported measure of
segment profit or
 loss upon the adoption of ASU 2023-07 and now disclose gross profit for
each
 segment in addition to revenues. In your MD&A, however, you continue to
 present Income from operations for each segment, which includes reported
amounts of
 sales and marketing, general and administrative and research and
development
 expenses. Please clarify for us whether Income from operations for each
segment is
 reported to the CODM and the extent to which this measure is used to
evaluate
 segment performance and allocate resources. To the extent this measure
is considered
 by the CODM when assessing performance and allocating resources, please
explain
 how you determined the appropriate measure(s) to report under ASC
280-10-50-
 April 24, 2025
Page 2

 28A. In this regard, at least one of the reported segment profit or loss
measures shall
 be that which management believes is determined in accordance with the
 measurement principles most consistent with those used in measuring the
 corresponding amounts in your consolidated financial statements.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
</DOCUMENT>

August 6, 2019
Brian P. McKeon
Executive Vice President, Chief Financial Officer and Treasurer
IDEXX Laboratories, Inc.
One IDEXX Drive
Westbrook Maine 04092
Re:IDEXX Laboratories, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 15, 2019
File No. 000-19271
Dear Mr. McKeon:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance

CORRESP
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July 31, 2019

Mr. Mark Brunhofer

Division of Corporation Finance

Office of Healthcare & Insurance

United States Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: IDEXX Laboratories, Inc.

Form 10-K for the Fiscal Year Ended December
31, 2018

Filed on February 15, 2019

File No. 000-19271

Dear Mr. Brunhofer:

This letter sets forth below the detailed
response of IDEXX Laboratories, Inc. and its wholly-owned and majority-owned subsidiaries (collectively, “we”, “us”
or the “Company”) to the comment of the Staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) in its letter to the Company dated July 19, 2019 with respect to the above-referenced Form 10-K (the
“2018 Form 10-K”). In responding to the Staff’s comment, our response is preceded by a reproduction of the Staff’s
comment. This letter has been filed with the Commission as correspondence through EDGAR.

We understand that you will be reviewing
our response 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 Fiscal Year Ended December 31, 2018

Notes to Consolidated Financial Statements

Note 3: Revenue Recognition, page F-18

Staff Comment:

On page F-19 you disclose that diagnostic
products and accessories revenues (including consumables) are recognized and invoiced at the time of shipment, which is when the
customer obtains control of the product based on legal title transfer. On page 35, you disclose that SediVue Dx consumables are
charged to customers upon utilization, which you refer to as pay-per-run. Please tell us your policy for recognizing revenue for
SediVue Dx consumables and how your recognition conforms with your disclosed recognition policy. In your response, tell us why
you do not charge a customer until after utilization and clarify when title passes. Reference for us the authoritative literature
relied upon to support your accounting.

IDEXX Laboratories, Inc.

One IDEXX Drive, Westbrook, Maine
04092 USA, idexx.com

1-207-556-0300     1-800-548-6733     f.
1-207-556-4346

Mr. Mark Brunhofer

United States Securities and Exchange Commission

July 31, 2019

Page 2

IDEXX Response:

SediVue Dx consumable revenues are recognized
upon customer utilization and represented less than 1% of IDEXX revenues for the year ended December 31, 2018. The Company’s
revenue recognition policy for SediVue Dx differs from other IDEXX diagnostic products and accessories. For these other products
the customer obtains control and revenue is recognized at the time of shipment.

The Company implemented a pay-per-run invoicing
model to incentivize adoption of the new automated urinalysis technology introduced with the SediVue Dx analyzer in 2016. The pay-per-run
invoicing model is intended to improve customer adoption rates by removing the cost to hold SediVue Dx consumables inventory. The
Company monitors the utilization of SediVue Dx consumables and automatically delivers enough consumables to ensure customers have
adequate inventory on-hand based on their anticipated usage. We believe that this auto-replenishment program further improves customer
adoption rates by removing the need for customers to monitor and order inventory. Customers receive one monthly invoice for SediVue
Dx consumables based on utilization and have no obligation to pay for or return unused or damaged consumables.

The Company considered the guidance
on transfer of control in paragraphs ASC 606-10-25-23 through 25-26, as well as the indicators of transfer of control
as described in ASC 606-10-25-30 in determining the revenue recognition policy for SediVue Dx consumables. The Company
concluded that transfer of control for consumables sold under a pay-per-run arrangement occurs at the time consumables are
utilized. The Company concluded control of the consumables transferred upon utilization of the consumable because that is the
point when the Company has a present right to payment and the risks and rewards of ownership transfer, which we believe are
the key indicators in this assessment. While other control indicators such as legal title passing to customers upon shipment
and physical possession by customers upon delivery, we do not believe these factors would change this assessment.

The Company’s revenue recognition
policy for SediVue Dx consumables is not described in Note 3: Revenue Recognition because, as discussed above, Sedivue Dx
consumable revenues are not material to IDEXX revenues. However, in response to the Staff’s comment, the Company intends
to include in its future periodic filings, beginning with the June 30, 2019 Form 10-Q, revised disclosure to clarify that diagnostic
products and accessories revenues are predominately recognized at the time of shipment. The revised disclosure will be similar
to the following (change in bold type face), based on the Notes to the Consolidated Financial Statements, Note 3: Revenue
Recognition, Diagnostic Products and Accessories on page F-19 in the Company’s 2018 Form 10-K:

Mr. Mark Brunhofer

United States Securities and Exchange Commission

July 31, 2019

Page 3

“Diagnostic Products
and Accessories. Diagnostic products and accessories revenues, including IDEXX VetLab consumables and accessories, rapid assay,
LPD, Water, and OPTI testing products, are predominantly recognized and invoiced at the time of shipment, which is when
the customer obtains control of the product based on legal title transfer and we have the right to payment. Shipping costs reimbursed
by the customer are included in revenue and cost of sales. As a practical expedient, we do not account for shipping activities
as a separate performance obligation.”

Further, in response to the Staff’s
comments and to clarify the Company’s reference to pay-per-run within the Description of Business Segments as part of Management’s
Discussion and Analysis of Financial Condition and Results of Operations, the Company intends to include in its future filings,
beginning with the 2019 Form 10-K, expanded disclosure related to revenue recognition for consumables similar to the following
(changes in bold type face).

“Our SediVue Dx instrument
was launched in North America early in 2016 and in the U.K. and Australia in the fourth quarter of 2016. During 2017, we continued
to launch SediVue Dx internationally. As of December 31, 2018, our premium SediVue Dx analyzers provided for an active installed
base of nearly 6,600 units globally, as compared to approximately 4,000 units in 2017 and approximately 1,500 units in 2016. This
instrument and single-use consumable system provides a highly accurate way to automate the process of examining urine under a microscope. We
provide customers with SediVue Dx consumables that are charged upon utilization, which we refer to as pay-per-run, as compared
to other instruments where we charge upon shipment of consumables. This pay-per-run consumable revenue stream is contributing
to our continuing growth, however is not currently material relative to IDEXX’s overall revenue.”

*************************

We hope that the foregoing satisfactorily
responds to the Staff’s comment. We request that should you require further clarification or additional information, please
direct any questions or comments regarding the foregoing to Brian P. McKeon, our Chief Financial Officer, at (207) 556-6396.

Sincerely,

/s/ Brian P. McKeon

Chief Financial Officer

 cc: Mr. Jim Rosenberg, Office of Healthcare and Insurance, Division of Corporation Finance, U.S.
Securities and Exchange Commission

Ms. Sharon E. Underberg, General Counsel

July 19, 2019
Brian P. McKeon
Executive Vice President, Chief Financial Officer and Treasurer
IDEXX Laboratories, Inc.
One IDEXX Drive
Westbrook Maine 04092
Re:IDEXX Laboratories, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 15, 2019
File No. 000-19271
Dear Mr. McKeon:
            We have reviewed your filing and have the following comment.  In our comment, we ask
you to provide us with information so we may better understand your disclosure.
            Please respond to this comment within 10 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2018
Notes to Consolidated Financial Statements
Note 3: Revenue Recognition, page F-18
1.On page F-19 you disclose that diagnostic products and accessories revenues (including
consumables) are recognized and invoiced at the time of shipment, which is when the
customer obtains control of the product based on legal title transfer.  On page 35, you
disclose that SediVue Dx consumables are charged to customers upon utilization, which
you refer to as pay-per-run.  Please tell us your policy for recognizing revenue for
SediVue Dx consumables and how your recognition conforms with your disclosed
recognition policy. In your response, tell us why you do not charge a customer until after
utilization and clarify when title passes.  Reference for us the authoritative literature relied
upon to support your accounting.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameBrian P. McKeon
 Comapany NameIDEXX Laboratories, Inc.
 July 19, 2019 Page 2
 FirstName LastName
Brian P. McKeon
IDEXX Laboratories, Inc.
July 19, 2019
Page 2
            You may contact Mark Brunhofer at (202) 551-3638 or Jim Rosenberg at (202) 551-
3679 with any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance

October 31 , 201 3

Via E -mail
Mr. Jonathan W. Ayers
Chairman, President and
Chief Executive Officer
IDEXX Laboratories, Inc.
One Idexx  Drive,
Westbrook , Maine  04092

Re:  IDEXX Laboratories, Inc.
 Form 10 -K for the Fiscal Year Ended December 31, 2012
Filed February 19, 201 3
File No. 000-19271

Dear Mr. Ayers:

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securitie s laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing  to be certain that the filing include s the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

/s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant

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

CORRESP
1
filename1.htm

SEC Letter

 September 12, 2013

By EDGAR Submission

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, DC 20549

Attention:
Jim B. Rosenberg

Senior Assistant Chief Accountant

          Re:
IDEXX Laboratories, Inc.

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

Filed February 19, 2013

File No.
000-19271

 Dear
Mr. Rosenberg:

 This letter relates to the letter dated September 9, 2013 (the “Letter”) to IDEXX Laboratories, Inc. (the
“Company”) from Jim B. Rosenberg, Senior Assistant Chief Accountant, on behalf of the Staff (the “Staff”) of the U.S. Securities and Exchange Commission.

In the letter, Mr. Rosenberg requests that the Company submit to the Staff a response to the comments contained in the Letter within 10 business days or
an indication from the Company as to when it intends to provide the Staff with a response. The Company respectfully requests that the date by which the Company must respond to the Letter be extended to Monday, October 7, 2013.

If you require additional information or wish to discuss the timing of the Company’s response, please do not hesitate to contact me at 207-556-3825.

Very truly yours,

 /s/ Willard Blanche Jr.

Chief Financial Officer

 cc: James Peklenk, Staff Accountant

 One IDEXX Drive, Westbrook ME 04092

September 9, 201 3

Via E -mail
Mr. Jonathan W. Ayers
Chairman, President and
Chief Executive Officer
IDEXX Laboratories, Inc.
One Idexx  Drive,
Westbrook , Maine  04092

Re:  IDEXX Laboratories, Inc.
 Form 10 -K for the Fiscal Year Ended December 31, 2012
Filed February 19, 201 3
File No. 000-19271

Dear Mr. Ayers :

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 document.  In our comment s, we ask
you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by providing the requested
information or by advising  us when you will provide the requested response.  If you do not
believe  a comment appl ies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label CORRESP  that keys your
response s to our comment s.

After reviewing the information provided, we may have additional comments and/or
request that you amend your filing.

Business
Patents and Licenses, page 10

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 licens e 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 decrea ses in revenues and
asset impairments.

Mr. Jonathan W. Ayers
IDEXX Laboratories, Inc.
September  9, 201 3
Page 2

 Management’s Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting P olicies and Estimates
Revenue Recognition, page 35

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 rega rd, address w hat is being netted and the amounts.

Notes To Consolidated Financial Statements
Note 2.  Summary of Significant Accounting Policies
(i)  Revenue Recognition

Multiple element arrangements (“MEAs”), page F -12

3. Please refer to your disclosure in the second paragraph regarding arrangements that
include a separately -priced EMA in which you recognize revenue related to the EMA at
the stated contractual price on a straight -line basis over the life of the agreement to  the
extent the separately stated price is substantive.  Please provide us your accounting
analysis supporting use of the stated contractual price with reference to authoritative
literature.  In addition, regarding your disclosure that if there is no state d contractual price
for an EMA, or the separately stated price is not substantive, clarify for us what is meant
by the statement that you recognize revenue according to the MEA policy stated above.
Further, regarding your disclosure for contracts within the scope of softw are revenue
recognition in the third paragraph, tell us how you determine the amount related to
EMA’s.

Customer Programs
Reagent Rental Programs, page F -14

4. Please provide us your analysis supporting your accounting for these programs with
reference to a uthoritative literature.  In your response, tell us the carrying amount of the
instruments and the deferred revenue for these programs as of December 31, 2012.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the  filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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.

Mr. Jonathan W. Ayers
IDEXX Laboratories, Inc.
September  9, 201 3
Page 3

In responding to our comment s, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy and accuracy of the disc losure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 the company may not assert staff comments as a defense in any proceeding init iated by
the Commission or any person under the federal securities laws of the United States.

Please contact James Peklenk, Staff Accountant, at (202) 551 -3661 if you have any
questions regarding the comment s.  In this regard, do not hesitate to contact me at (202) 551 -
3679.
Sincerely,

/s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant

September 10 , 2012

Via E -mail
Mr. Jonathan Ayers
Chief Executive Officer and President
IDEXX L aboratories, Inc .
One IDEXX Drive
Westbrook, M E  04092

Re: IDEXX Laboratories, Inc.
Form 10-K for the Y ear Ended December 31 , 2011
Filed February 17, 2012
File No. 000-19271

Dear Mr. Ayers :

We have comp leted our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing 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.  We u rge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Gus Rodriguez

Gus Rodriguez
Accounting Branch Chief

CORRESP
1
filename1.htm

SEC Letter

 August 20, 2012

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, 2011

Filed on February 17, 2012

File No. 000-19271

 Dear Mr. Rosenberg:

 Please see our responses below to your letter dated August 6, 2012. Each of our responses is preceded by a reproduction of the
corresponding numbered or bulleted Staff comment.

 In connection with responding to the Staff’s comments, IDEXX Laboratories, Inc.
(“the Company”) acknowledges 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
filing; 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.

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

 Critical Accounting Policies and Estimates

 Revenue Recognition, page 31

 Comment:

1.
It appears, based on the information in the tables presented on page 33, that your Up-Front Customer Loyalty Programs experienced significant volume growth in 2010
and 2011. Please address the following comments:

•

 Please summarize for us the terms of your Up-Front Customer Loyalty Programs. In your response, please clarify whether your incentives to customers
upon entering into agreements are in the form of cash payments and, if so, whether they are refundable. If

Mr. Jim B. Rosenberg

 United States Securities and Exchange Commission

 August 20, 2012

 Page 2

 not, please explain what incentives are provided.
Also clarify how these incentives are applied against the future delivery of products or provision of services.

 Response:

 IDEXX provides up-front incentives to customers in the form of cash payments or IDEXX Points in exchange for entering a
multi-year agreement to purchase annual minimum amounts of future reference laboratory services. IDEXX Points are deposited in customer loyalty point accounts, a liability on our balance sheet, and represent credits that may be applied against the
purchase price of IDEXX products or services purchased in the future or applied to trade receivables owed to us. If a customer breaches its agreement, it is required to refund a prorated portion of the up-front cash or IDEXX Points.

Comment:

•

 Please provide us your analysis supporting why capitalization of these incentives as customer acquisition costs is appropriate and reference for us
the authoritative literature you rely upon to support your accounting. To the extent you rely in part on the guidance in ASC 605-50-25-3, please explain to us how your arrangements are “single exchange transactions” as contemplated in that
guidance and how your arrangements are not precluded from accounting under ASC 605-50 as stipulated in the scope paragraph in ASC 605-50-15-3.

 Response:

 We do not believe the scope paragraph in ASC 605-50-15-3
precludes us from the scope of ASC 605-50 because the up-front consideration we are providing to customers represents cash consideration as defined in ASC 605-50-20 and, as stipulated in the scope paragraph in ASC 605-50-15-2 a.2., our up-front
customer incentives represent cash consideration that are redeemable only if our customers complete a specified cumulative level of revenue transactions and remain a customer for a specified time period, and do not provide us with an identifiable
benefit. Therefore, we believe our up-front customer incentive programs are within the scope of ASC 605-50. Specifically, in accordance with ASC 605-50-25-7, our up-front cash consideration incentives are recognized as a reduction of revenue based
on a systematic and rational approach in proportion to the underlying revenue transactions that will result in progress by the customer toward earning the incentive. Our analysis considered that: (a) our up-front customer incentives provided in
the form of both cash and IDEXX Points are considered cash consideration as defined in ASC 605-50-20 which includes credits the customer can apply against trade amounts owed to the vendor; (b) as stated in our response above, our agreements
with our customers require a specified cumulative level of revenue transactions over a specified period of time, and are refundable to us if the purchase commitment agreement is breached; and (c) we do not receive an identifiable benefit in
exchange for the up-front consideration to our customers, as it is not sufficiently separable from the recipient’s purchase of our products such

Mr. Jim B. Rosenberg

 United States Securities and Exchange Commission

 August 20, 2012

 Page 3

 that we could have entered into an exchange transaction with a party
other than a purchaser of our services in order to receive the benefit. We have not relied on the guidance in ASC 605-50-25-3 as these programs are not single exchange transactions.

We further believe that the criteria outlined in ASC 605-50-45-9 are helpful when evaluating whether the up-front consideration can be
capitalized as an asset. Specifically, our up-front customer incentives provide us with both (a) the right to be the provider of reference laboratory services for a specified period of time and it is probable the customer will order our
services, and (b) requires the customer to order a minimum amount of our services in the future. In addition to the guidance in ASC 605-50, the analogous guidance provided in ASC 605-20-25-4 also supports the capitalization of our up-front
customer incentives. Our up-front customer incentives represent costs that are directly related to the acquisition of a customer contract that would not have been incurred but for the acquisition of that contract. We believe these incentives are
analogous to incremental direct acquisition costs associated with a probable revenue stream supported by our customer’s obligation to purchase minimum amounts of reference laboratory services during the contract term. Based on the analogous
guidance provided in ASC 605-20-25-4 these costs should be deferred. We believe the SEC Staff guidance that “incremental direct costs incurred related to the acquisition or origination of a customer contract that results in the deferral of
revenue, unless specifically provided for in the authoritative literature, may be either expensed as incurred or accounted for in accordance with ASC 605-20-25-4 or ASC 310-20-35-2” as stated in Staff Accounting Bulletin Topic 13.A.1, f.
Nonrefundable Up-Front Fees, Question 3, and codified in ASC 605-10-S99, supports our analogous reference to ASC 605-20-25-4 above and further to the analogous definition of Incremental Direct Costs contained in ASC 310-20-20.

Comment:

•

 Please provide us a sample of journal entries for a reasonable hypothetical transaction under your Up-Front Customer Loyalty Program that
demonstrates from contract inception to completion how you record revenue and costs, including the operation of your incentives. In this regard, it is unclear how you generated $21.3 million in credits to your accrued customer programs liability
account in 2011 when only $4.0 million appears to be recorded as a debit to revenues. It is also unclear whether and, if so, how the $35.6 million in IDEXX Points redeemed and credits issued in 2011 relates to your Up-Front Customer Loyalty
Programs.

 Response:

 Set forth below is a sample of journal entries for a reasonably hypothetical transaction where IDEXX pays a customer $100,000 in cash or IDEXX Points as an up-front incentive in exchange for entering a
contractual agreement to purchase a specified annual minimum of $100,000 in reference laboratory services and remain a customer for a 5 year period. If during

Mr. Jim B. Rosenberg

 United States Securities and Exchange Commission

 August 20, 2012

 Page 4

 any annual period the customer does not meet the annual minimum, then
$20,000 of cash or IDEXX Points, as applicable, is required to be refunded to IDEXX. This represents the prorated portion of the up-front incentive related to that annual period.

 (Amounts in thousands)

a)
Upon cash payment to the customer at the inception of the agreement:

 Customer acquisition asset

Debit

$
100

 Cash

Credit

($
100
)

b)
Alternatively, upon award of IDEXX points to the customer at the inception of the agreement:

 Customer acquisition asset

Debit

$
100

 Accrued Customer Programs

Credit

($
100
)

c)
Revenue is recognized as reference laboratory services are provided over the term of the agreement:

Year 1

Year 2

Year 3

Year 4

Year 5

 Trade Accounts Receivable

Debit

$
100

$
100

$
100

$
100

$
100

 Revenue

Credit

($
100
)

($
100
)

($
100
)

($
100
)

($
100
)

d)
The customer acquisition asset is amortized over the term of the agreement as a reduction of revenue:

Year 1

Year 2

Year 3

Year 4

Year 5

 Revenue

Debit

$
20

$
20

$
20

$
20

$
20

 Customer acquisition asset

Credit

($
20
)

($
20
)

($
20
)

($
20
)

($
20
)

e)
Upon the customer’s utilization of IDEXX points;

 Accrued Customer Programs

Debit

$
100

 Trade Accounts Receivable

Credit

($
100
)

 The following intends to add clarity to the relationship between the questioned amounts in the tables
presented on page 33 of our 2011 Form 10-K.

 The $21.3 million in credits to accrued customer programs related to our Up-Front
Customer Loyalty Programs represents only up-front incentives provided to customers in the form of IDEXX Points during 2011 (as illustrated in journal entry b) above). In addition to the $21.3 million in credits to accrued customer programs, credits
directly to cash for up-front incentives provided to customers in the form of cash during 2011 was $6.2 million.

 Mr. Jim B. Rosenberg

 United States Securities and Exchange Commission

 August 20, 2012

Page 5

 The $4.0 million in debits to revenue related to our Up-Front Customer Loyalty Programs represents the amortization of customer acquisition costs during 2011 for both up-front incentives provided to
customers in the form of cash and IDEXX Points (as illustrated in journal entry d) above). Given the up-front incentives are amortized over a multi-year period, we would not expect a direct correlation between the debits to revenue and the credits
to accrued customer programs.

 The $35.6 million in IDEXX Points redeemed and credits issued represents the usage of IDEXX
Points during 2011 by all IDEXX customers who earn IDEXX Points through our Customer Loyalty Programs including our Up-Front Customer Loyalty Program (as illustrated in journal entry e) above). The redemptions specific to each of our programs,
including our Up-Front Customer Loyalty Program are not presented separately because IDEXX Points earned from multiple programs are combined once deposited in customer loyalty point accounts.

 Comment

•

 Please tell us your consideration for discussing your apparent increased use of these loyalty programs in your results of operations and liquidity
discussions.

 Response:

 The increased use of our Up-Front Customer Loyalty Program contributed nearly 2% to the total reported growth of 13% in our Reference Laboratory Diagnostic and Consulting Services line of business during
2011. This increase in reference laboratory testing volumes as a result of new customer acquisitions was addressed in our discussion of organic revenue drivers on page 40 of our 2011 Form 10-K, as follows:

“The increase in reference laboratory diagnostic and consulting services revenue resulted primarily from the impact of higher
testing volumes and, to a lesser extent, price increases. Higher testing volumes were driven by the acquisition of new customers due, in part, to geographic expansion and our customer loyalty programs in which customers are provided incentives in
the form of IDEXX Points or cash in exchange for agreements to purchase services in future periods.”

 We considered
our Up-Front Customer Loyalty Program and the up-front incentives provided to customers in the form of cash of $6.2 million during 2011 to be immaterial compared to other drivers in our overall liquidity discussion and we do not currently expect
these programs to become material to our liquidity in future periods.

 Mr. Jim B. Rosenberg

 United States Securities and Exchange Commission

 August 20, 2012

Page 6

 If you have any questions regarding the foregoing, please do not hesitate to contact me at (207) 556-4446.

Sincerely,

 /s/ Merilee Raines

Executive Vice President, Chief Financial Officer and Treasurer

cc:
Mark Brunhofer, Senior Staff Accountant

Kei Nakada, Staff Accountant

CORRESP
1
filename1.htm

SEC letter

 August 10, 2012

 By EDGAR Submission

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 100 F Street,
N.E.

 Washington, DC 20549

Attention:
Jim B. Rosenberg

Senior Assistant Chief Accountant

Re:
IDEXX Laboratories, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2011

Filed February 17, 2012

File No.
000-19271

 Dear Mr. Rosenberg:

 This letter relates to the letter dated August 6, 2012 (the
“Letter”) to IDEXX Laboratories, Inc. (the “Company”), from Mr. Jim B. Rosenberg, Senior Assistant Chief Accountant, on behalf of the Staff (the “Staff”) of the U.S. Securities and Exchange Commission.

 In the letter, Mr. Rosenberg requests that the Company submit to the Staff a response to the comments contained in the Letter within 10
business days or an indication from the Company as to when it intends to provide the Staff with a response. The Company respectfully requests that the date by which the Company must respond to the Letter be extended to Friday, August 31, 2012.

 If you require additional information or wish to discuss the timing of the Company’s response, please do not hesitate to contact me at
207-556-8279.

 Very truly yours,

/s/ Jennifer L. Panciocco

 Associate General
Counsel

cc:
Kei Nakada, Staff Accountant

Mark Brunhofer, Senior Staff Accountant

August 6, 2012

Via E -mail
Mr. Jonathan Ayers
Chief Executive Officer and President
IDEXX L aboratories, Inc .
One IDEXX Drive
Westbrook, M E  04092

Re: IDEXX Laboratories, Inc.
Form 10-K for the Y ear Ended December 31 , 2011
Filed February 17, 2012
File No. 000-19271

Dear Mr. Ayers :

We have reviewed your filing  and have the following comment .  In our comment , we ask
you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by providing the requested
information or by advising us when you will provide the requested response.   If you do not
believe the comment applies to your facts and circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that key s
your response  to our comment .

After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

Management’s Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies and Estimates
Revenu e Recognition, page 31

1. It appears, based on the information in the tables presented on page 33, that your Up -
Front Customer Loyalty Programs experienced significant volume growth in 2010 and
2011.  Please address the following comments:
 Please summarize for us the terms of your Up -Front Customer Loyalty Programs.  In
your response, please clarify whether your incentives to customers upon entering into
agreements are in the form of cash payments and, if so, whether they are refundable.
If not, please expl ain what incentives are provided.  Also clarify how these incentives
are applied against the future delivery of products or provision of services.
 Please provide us your analysis supporting why capitalization of these incentives as
customer acquisition cos ts is appropriate and reference for us the authoritative
literature you rely upon to support your accounting.  To the extent you rely in part on

Mr. Jonathan Ayers
IDEXX L aboratories, Inc .
August 6, 2012
 Page 2

 the guidance in ASC 605 -50-25-3, please explain to us how your arrangements are
“single exchange transactions” as contemplated in that guidance and how your
arrangements are not precluded from accounting under ASC 605 -50 as stipulated in
the scope paragraph in ASC 605 -50-15-3.
 Please provide us a sample of journal entries for a reasonable hypothetical transaction
under your Up -Front Customer Loyalty Program that demonstrates from contract
inception to completion how you record revenue and costs, including the operation of
your incentives.  In this regard, it is unclear how you generated $21.3 million in
credits to y our accrued customer programs liability account in 2011 when only $4.0
million appears to be recorded as a debit to revenues.  It is also unclear whether and,
if so, how the $35.6 million in IDEXX Points redeemed and credits issued in 2011
relates to your Up-Front Customer Loyalty Programs.
 Please tell us your consideration for discussing your apparent increased use of these
loyalty programs in your results of operations and liquidity discussions.

We urge all persons who are responsible for the accuracy an d adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relati ng to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment , please provide a written statement from the company
acknowledging that:

 the company is responsible for th e adequacy and accuracy of the disclosure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; 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.

Please contact Kei Nakada, Staff Accountant, at (202) 551 -3659 or Mark Brunhofer,
Senior Staff Accountant, at (202) 551 -3638  if you have questions regarding the comments.  In
this regard , do not hesitate to contact me  at (202) 551 -3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant

Via Facsimile and U.S. Mail

         August 20 , 2010

Conan R. Deady
Corporate Vice President, General Counsel and Secretary
Idexx Laboratories, Inc.
One Idexx Drive
Westbrook, Maine  04092

Re:   Idexx Laboratories, Inc.
 Form 10 -K for the Fis cal Year Ended December 31, 200 9
 Filed February 19, 2010
 File Number:  000-19271

Dear M r. Deady :

We have completed our review of your filing and do not have any further
comments at this time.

        Sincerely,

        Jeffrey P. Riedler
        Assistant Director

CORRESP
1
filename1.htm

    corresp20100714.htm

July 14, 2010

Jeffrey P. Riedler

Assistant Director

Division of Corporation Finance

United States Securities and Exchange Commission

Re:          IDEXX Laboratories, Inc.

Form 10-K for Fiscal Year Ended December 31, 2009

Filed on February 19, 2010

File No. 000-19271

Dear Mr. Riedler:

Please see our responses below to your letter dated July 1, 2010.  Each of our responses is preceded by a reproduction of the corresponding numbered Staff comment.

In connection with responding to the Staff’s comments, we acknowledge that:

·

We, the Company, are 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 filing; and

·

We, 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.

Form 10-K December 31, 2009

Item 1.  Business

Production and Supply, page 9

Comment:

1.

Please be advised that we cannot clear our review of your annual report on Form 10-K until your agreement with Moss, Inc. has been filed.

Mr. Jeffrey P. Riedler

United States Securities and Exchange Commission

July 14, 2010

Page 2

Response:

We confirm that we will file our agreement with Moss as an exhibit with the Form 10-Q for the second quarter of 2010, subject to a request for confidential treatment for portions of the agreement.  We anticipate that we will file our Form 10-Q on or about July 23, 2010.

Patents and Licenses, page 9

Comment:

2.

We note your response to our prior comment 3.  Please confirm that you will include this information in your response in future filings.

Response:

In future Form 10-K filings, beginning with the Form 10-K for the 2010 fiscal year, we confirm that we will disclose that the patented technology for the detection of Lyme disease is utilized in certain of our SNAP® products and a reference laboratory test, and that the patented technology for the detection of FIV antibodies is utilized in certain of our SNAP® products.

Definitive Proxy Statement on Schedule 14A

Compensation Discussion & Analysis, page 22

3.

We note your response to comment 9 and your statement that the Committee’s subjective determination is based on those factors it deems relevant.  Please confirm that in future years you will discuss all factors that the Committee considered in determining bonuses.  Also, to the extent that individual goals are set, please confirm that you will discuss the level of achievement and how the level of achievement was used to determine bonuses.  If the level of achievement is not considered by the Committee, you should discuss the factors that were considered and why the individual goals were not considered.

Response:

In future proxy statements, beginning with the proxy statement for our 2011 annual meeting of shareholders, we will discuss all material factors that the Committee considered in making its subjective determination of discretionary bonuses.

As described in our proxy statement, each named executive officer’s goals are established as part of the company’s general performance management process, which is not directly related to compensation.

·

In the event the level of achievement of these goals is considered by the Committee in its determination of discretionary bonuses, to the extent that level of achievement is

Mr. Jeffrey P. Riedler

United States Securities and Exchange Commission

July 14, 2010

Page 3

substantially the same across the group of named executive officers, we will discuss the level of achievement of these goals as a group, in a manner similar to our discussion in our letter to you of June 11, 2010 (i.e., the Committee’s overall assessment of each executive’s performance in 2009 was that on the whole they achieved their respective goals), and how the level of achievement impacted the Committee’s subjective bonus determinations.  To the extent there are material differences among the percentage of target bonus amounts awarded to the named executive officers, we will discuss the Committee’s specific assessments of relative goal achievement that are material for an understanding of the bonus awards.

·

In the event that the level of achievement of these goals is not considered by the Committee, we will discuss the material factors that were considered by the Committee and why the level of achievement of these goals was not considered.

If you have any questions regarding the foregoing, please do not hesitate to contact me at (207) 556-4920.

Sincerely,

/s/ Conan R. Deady

Corporate Vice President, General Counsel and Secretary

cc:  Suzanne Hayes

       Branch Chief

Via Facsimile and U.S. Mail

         July 1 , 2010

Conan R. Deady
Corporate Vice President, General Counsel and Secretary
Idexx Laboratories, Inc.
One Idexx Drive
Westbrook, Maine  04092

Re:   Idexx Laboratories, Inc.
 Form 10 -K for the Fis cal Year Ended December 31, 200 9
 Filed February 19, 2010
 File Number:  000-19271

Dear M r. Deady :

We have reviewed your response filed with us on June 11, 2010  and have the
following comment s.  In our comment s, we ask you to provide us with information to
better understand your disclosure. The information you provide should show us what the
revised disclosure will look like and identify the annual or quarterly filing, as applicable,
in which you intend to first include it. If you do not believe that revi sed disclosure is
necessary, explain the reason in your response. After reviewing the information provided,
we may raise additional comments and/or request that you amend your filing.

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

Conan R. Deady
Idexx Laboratories, Inc.
July 1 , 2010
Page 2

Annual Report on Form 10 -K

Item 1. Business

Production and Supply , page 9

1. Please be advised that we cannot clear our review of your annual report on F orm
10-K until your agreement with Moss, Inc. has been filed.

Patents and Licenses, page 9

2. We note your response to our prior comment 3. Please confirm that you will
include this information in your response in future filings.

Schedule 14A

Compensatio n Discussion & Analysis, page 22

3. We note your response to comment 9 and your statement that the Committee’s
subjective determination is based on those factors it deems relevant.  Please
confirm that in future years you will discuss all factors that the Co mmittee
considered in determining bonuses. A lso, to the extent that individual goals are
set, please confirm that you will discuss the level of achievement and how the
level of achievement was used to determine bonuses. If the level of achievement
is not c onsidered by the Committee, you should discuss the factors that were
considered and why the individual goals were not considered.

* * * *

 Please provide us the information requested  within 10 business days or tell us
when you will provide us with a re sponse.  Please furnish a cover letter with your response
that keys your response to our comments.  Detailed cover letters greatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing include 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.

Conan R. Deady
Idexx Laboratories, Inc.
July 1 , 2010
Page 3

 In connection with responding to ou r comments, please provide, in your letter, a
statement from the company acknowledging that:

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

 staff comments or changes to disclosure in response to staff comments d o not
foreclose the Commission from taking any action with respect to the filing;
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 filing or in response to our comments on your filing.

Please contact Scot Foley  at (202) 551 -3383, Suzanne Hayes, Branch Chief, at
(202) 551 -3675 or me at (202) 551 -3715 with any questions.

        Sincerely,

        Jeffrey P. Riedler
        Assistant Director

CORRESP
1
filename1.htm

    corresp20100611.htm

June 11, 2010

Jeffrey P. Riedler

Assistant Director

Division of Corporation Finance

United States Securities and Exchange Commission

Re:          IDEXX Laboratories, Inc.

Form 10-K for Fiscal Year Ended December 31, 2009

Filed on February 19, 2010

File No. 000-19271

Dear Mr. Riedler:

Please see our responses below to your letter dated May 20, 2010.  Each of our responses is preceded by a reproduction of the corresponding numbered Staff comment.

In connection with responding to the Staff’s comments, we acknowledge that:

·

We, the Company, are 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 filing; and

·

We, 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.

Form 10-K December 31, 2009

Item 1.  Business

Production and Supply, page 9

Comment:

1.

You have disclosed that you purchase some products, raw materials and components from a single supplier.  Please identify your sole source suppliers, describe the material terms of the supply agreement and file the agreements as exhibits.  To the extent you believe you are not substantially dependent on these agreements, please provide your analysis supporting your determination.

Mr. Jeffrey P. Riedler

United States Securities and Exchange Commission

June 11, 2010

Page 2

Response:

As described in the Business section of our 2009 Form10-K, some of the third parties that provide us with instruments we sell and certain components, raw materials and consumables incorporated into, or used with, our products are obtained from sole or single source suppliers.  We define sole source suppliers as those third party suppliers that provide a raw material, component, or product for which we have not identified any other viable supplier.  We define single source suppliers as those third party suppliers from which we elect to purchase all of our supplies of a particular raw material, component, or product that is also available from one or more other viable suppliers.

We believe that we are not substantially dependent on any of our single source suppliers because, in the event of a significant disruption in supply of raw materials, components, or products by such a supplier, we would be able to source equivalent raw materials, components, or products from alternative suppliers in a commercially reasonable time frame without disruption to our business.

We currently have eight sole source suppliers.  With respect to four of such suppliers, 2009 revenues from the sale of products supplied by such suppliers or from the sale of products incorporating raw materials or components supplied by such suppliers, as the case may be, were less than 1% of our 2009 worldwide sales.  With respect to two of such suppliers, such revenues were between 1% and 1.9% of our 2009 worldwide sales.  Due to the immateriality of the relevant product sales to the Company as a whole, we believe that we are not substantially dependent on any of these six sole source suppliers and that any agreements with such suppliers need not be included as exhibits to our Form 10-K.  Further detail concerning the remaining two sole source suppliers is provided below.

Ortho

We have agreements with Ortho-Clinical Diagnostics, Inc.(“Ortho”) for the supply of our VetTest® and Catalyst Dx® chemistry slides.  We discuss this sole source relationship on page 9 of our 2009 Form 10-K and in our response to Comment #2 below. We have previously filed the agreements with Ortho as exhibits.

Moss

Moss, Inc. (“Moss”) is a sole source supplier of components that are incorporated into a number of our SNAP® single-use test kits.  Sales of SNAP® kits incorporating these components in 2009 were approximately 17% of our 2009 revenues. While we do not believe all SNAP® revenue is dependent on the components obtained from Moss, or that we are “substantially dependent” on the Moss agreement as that term is used in Item 601(b)(10)(ii)(B) of Regulation S-K, in future filings, beginning with the 10-Q for the second quarter of 2010, we will include our agreement with Moss as an exhibit.   In future Form 10-K filings, beginning with the Form 10-K for the

Mr. Jeffrey P. Riedler

United States Securities and Exchange Commission

June 11, 2010

Page 3

2010 fiscal year, we will include disclosure of the material terms of the Moss agreement, which are described in the following paragraph.

The supply agreement with Moss may be terminated by Moss with 24 months’ notice.  We are required annually to purchase a minimum amount from Moss equal to our average purchase volumes in 2004, 2005 and 2006.  Annual pricing increases are capped at 3%.  Pursuant to the terms of the supply agreement, Moss has escrowed its manufacturing information relating to the components, which may be released to us upon certain triggering events that would render Moss incapable of supplying the components to us.  If such a triggering event occurs, we will make royalty payments to Moss for the use of such information until Moss is able to again begin manufacturing.

Comment:

2.

Please describe the material terms of your supply agreements with Ortho-Clinical Diagnostics, Inc.

Response:

As noted on page 9 of our 2009 Form 10-K, we have agreements with Ortho for the supply of slides used in our chemistry analyzers that expire in 2025.  We are required to purchase a minimum volume of chemistry slides through the end of 2010; thereafter, we do not have minimum purchase obligations.  Price increases for slides are limited by a formula based on an agreed U.S. Producer Price Index.  The agreements limit the rights of Ortho to promote and sell chemistry slides in the veterinary market other than to IDEXX.  In future Form 10-K filings, beginning with the Form 10-K for the 2010 fiscal year, we will include this additional disclosure regarding the material terms of the Ortho agreement.

Patents and Licenses, page 9

3.

Please identify the products or classes of products related to patents related to the detection of Lyme disease and the detection of FIV antibodies.

Response:

As supplemental information, we advise the Staff that the products that utilize the patented technology for the detection of Lyme disease are SNAP® 3DX® and SNAP® 4DX®.   In addition, our reference laboratories offer a test called Lyme Quant C6® that utilizes this technology.

As supplemental information, we advise the Staff that the products that utilize the patented technology for detecting FIV antibodies are SNAP® Feline Triple®; SNAP® FELV/FIV Combo; and SNAP® Feline Combo Plus.

Mr. Jeffrey P. Riedler

United States Securities and Exchange Commission

June 11, 2010

Page 4

4.

Please describe the material terms of your agreements with Tulane University, the University of Texas, Boehringer Ingelheim and Cornell University and identify the products or class of products related to these license agreements.  Please either file these agreements as exhibits or provide us with an analysis supporting your determination that you are not substantially dependent of these agreements.

Response:

The products or laboratory tests that utilize the intellectual property covered by the agreements with Tulane University (“Tulane”) and the University of Texas (“Texas”) are Lyme Quant C6®, SNAP® 3DX® and SNAP® 4DX®.   Aggregate sales of these products and tests did not exceed 7% of the Company’s 2009 worldwide sales.  In addition, the SNAP® 3DX® and SNAP® 4DX® products test for three and four vector-borne diseases, respectively, only one of which (Lyme disease) utilizes the Tulane and Texas intellectual property.  A significant portion of the customer value associated with the SNAP® 3DX® and SNAP® 4DX® tests, therefore, is the detection of diseases other than Lyme disease, including canine heartworm, by means unrelated to the Tulane and Texas intellectual property.  For this reason we believe that the significance of the Tulane and Texas intellectual property to us is significantly overstated by analyzing aggregate revenues from the sale of these products relative to our total sales.  Nonetheless, even using this very conservative approach of looking at total revenue for all three products, we believe that we are still not substantially dependent on the agreements with Tulane and Texas, and that the agreements do not need to be included as exhibits to the Form 10-K.

The products that utilize the intellectual property covered by the agreement with Boehringer Ingelheim (“Boehringer”) are our porcine reproductive and respiratory test kits.  Sales of these test kits did not exceed 1% of our 2009 worldwide sales.  Therefore, we believe that we are not substantially dependent on the agreement with Boehringer and that such agreement need not be included as an exhibit to the Form 10-K.

The products that utilize the intellectual property covered by the agreement with Cornell University (“Cornell”) are our bovine viral diarrhea virus test kits.  Sales of these test kits did not exceed 1% of our 2009 worldwide sales.  Therefore, we believe that we are not substantially dependent on the agreement with Cornell and that such agreement need not be included as an exhibit to the Form 10-K.

Government Regulation, page 11

Comment:

5.

We note your statement that “compliance with an extensive regulatory process is required in connection with marketing diagnostic products in Japan, Germany, the Netherlands and many other countries.”  Please expand your disclosure to include a more detailed discussion of the regulatory processes in those countries and others outside the United States where you currently market your products, to the extent that your sales in these countries are material.

Mr. Jeffrey P. Riedler

United States Securities and Exchange Commission

June 11, 2010

Page 5

Response:

Our total sales of regulated products in any country other than the United States did not exceed 3% of our 2009 worldwide sales, which we do not consider to be material.  Accordingly, we do not believe any further disclosure regarding foreign regulatory processes is necessary at this time.

Item 1A. Risk Factors

Various Government Regulations Could Limit or Delay Our Ability to Market and Sell Our Products, page 14

6.

To the extent known, please expand your disclosure concerning the FTC’s investigation to state the actual practices you have engaged in that are at issue, including which products they concern, and what potential penalties you will be subject to if the FTC concludes that you have violated Section 5 of the Federal Trade Commission Act.

Response:

The FTC’s investigation is at an early stage and our disclosure regarding the scope of the investigation reflects our knowledge based on correspondence and discussions to date with the FTC.  At this time we are unable to describe the actual practices that are at issue with any further specificity because, to our knowledge, the FTC has not focused its investigation on particular practices beyond what we have disclosed in the risk factor.

Similarly, with respect to the relevant products, at this time we understand that the FTC is looking at all companion animal veterinary products and services, as disclosed in the risk factor, and we cannot describe the relevant products with any further specificity.  Our companion animal products and services are described in detail in the Form 10-K in the section entitled “Description of Business by Segment – Companion Animal Group.”

In any event, based on our understanding of the investigation, we have stated in the risk factor that we do not believe that any remedies that might be sought by the FTC, were the FTC to seek remedies following its investigation, would have a material adverse effect on the Company.  The FTC’s remedies under section 5 of the FTC Act are prospective in nature, and we do not believe that our business is materially dependent on our ability to continue any one or more marketing and sales practices relating to companion animal products and services in the U.S.

Definitive Proxy Statement on Schedule 14A

Nominating and Governance Committee, page 8

Mr. Jeffrey P. Riedler

United States Securities and Exchange Commission

June 11, 2010

Page 6

7.

Your disclosure concerning diversity on page 9 does not include a discussion of how the Nominating and Governance Committee has implemented this policy or how the Committee assesses its effectiveness.  Please revise your disclosure to include this information.  We refer you to Item 407(c)(2)(vi) of Regulation S-K.

Response:

We do not have a formal policy on diversity for Board members. Our Corporate Governance Guidelines provide that the value of diversity will be considered when the Board evaluates nominees to the Board and the composition of the Board as a whole.  In making the evaluations described in the prior sentence the Board also considers a range of other factors, including the experience, education, background, skills and knowledge of nominees and directors.  The Board does not make any particular weighting of diversity or any other characteristic in evaluating nominees and directors.

In future proxy statements, as applicable, beginning with the proxy statement for our 2011 annual meeting of shareholders, we will make clear that we do not have a formal diversity policy for Board members, but that diversity is considered as described above.

Election of Directors, page 17

Comment:

8.

Please identify the specific experience, qualifications, attributes or skills that led to the conclusion that each person should serve as a director as required by Item 401(e) of Regulation S-K.  Please note that your discussion on page 8 is not sufficient as the item requires a discussion of each individual’s experience, qualifications, attributes or skills, as opposed to a discussion of the board members’ collective experience, qualifications, attributes or skills.

Response:

We enhanced the biographies for each director in our 2010 proxy statement (beginning on page 17) in order to disclose the specific experience, qualifications, attributes and skills that led the Board to conclude that each person should serve as a director.  For example, below are the biographies for William T. End, our lead director, from the 2009 proxy statement and the 2010 proxy statement.  The 2010 biographical information contains significant additional information that is intended to be responsive to Item 401(e) of Regulation S-K.

On page 9 of our 2010 proxy statement, we stated that the Nominating and Governance Committee reviewed the experience, qualifications, attributes and skills for each director and nominee, as described for each director in his or her biography beginning on page 17, and concluded that each director had the requisite background to serve as a director in light of the

Mr. Jeffrey P. Riedler

United States Securities and Exchange Commission

June 11, 2010

Page 7

Company’s business and structure.  We therefore believe that the 2010 proxy statement included the information required under Item 401(e).

Mr. End’s biography from 2009 proxy statement (page 15)

William T. End, age 61, has been a director of IDEXX since July 2000. Mr. End was the Executive Chairman of the Board of Cornerstone Brands, Inc., a catalog retailer, from March 2001 until his retirement in June 2002, and served as Chairman and Chief Executive Officer of Cornerstone Brands, Inc. from 1995 until March 2001. From 1991 to 1995, Mr. End was employed by Land’s End, Inc., including as President and Chief Executive Officer, and from 1975 to 1991 he was employed by L.L. Bean, Inc., including as Executive Vice President. Mr. End is a director of Eddie Bauer

Via Facsimile and U.S. Mail
Mail Stop 4720

         May 20, 2010

Conan R. Deady
Corporate Vice President, General Counsel and Secretary
Idexx Laboratories, Inc.
One Idexx  Drive
Westbrook , Maine 04092

Re:   Idexx Lab oratories, In c.
 Form 10 -K for the Fiscal Year Ended December 31, 200 9
 Filed February 19, 2010
 File Number:  000-19271

Dear M r. Deady:

We have reviewed your filing and have the following comment s.  In our
comment s, we ask you to provide us with information  to better understand your
disclosure. The information you provide should show us what the revised disclosure will
look like and identify the annual or quarterly filing, as applicable, in which you intend to
first include it. If you do not believe that rev ised disclosure is necessary, explain the
reason in your response. After reviewing the information provided, we may raise
additional comments and/or request that you amend your filing.

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

Conan R. Deady
Idexx Laboratories, Inc.
May 20, 2010
Page 2

Annual Report on Form 10 -K

Item 1. Business

Production and Supply, page 9

1. You have disclosed that  you purchase some products, raw materials and
components from a single supplier.  Please identify your sole source suppliers,
describe the material terms of the supply agreement and file the agreements as
exhibits.  To the extent you believe you are not s ubstantially dependent on these
agreements, please provide your analysis supporting your determination.

2. Please describe the material terms of your supply agreements with Ortho -Clinical
Diagnostics, Inc.

Patents and Licenses, page 9

3. Please identify the products or classes of products related to patents related to the
detection of Lyme disease and the detection  of FIV antibodies.

4. Please describe the material terms of your agreements with Tulane  University , the
University of Texas, Boehringer Ingelheim and Cornell University and identify
the products or class of products related to these license agreements.  Please either
file th ese agreements as exhibits or provide us with an analysis supporting your
determination that you are not substantially dependent on these agreements.

Government Regulation, page 11

5. We note your statement that “compliance with an extensive regulatory process is
required in connection with marketing diagnostic products in Japan, Germany, the
Netherlands and many other countries.” Please expand your disclosure to include
a more detailed  discussion of the regulatory process es in those countries and
others outside the United States where you currently market your products, to the
extent that your sales in these countries are material.

Item 1A. Risk Factors

Various Government Regulation s Could Limit or Delay Our Ability to Market and Sell
Our Products, page 14

6. To the extent known,  please expand your disclosure concerning the FTC’s
investigation to state the actual practices you have engaged in that are at issue,
including which products  they concern, and what potential penalties you will be

Conan R. Deady
Idexx Laboratories, Inc.
May 20, 2010
Page 3

subject to if the FTC concludes that you have violated Section 5 of the Federal
Trade Commission Act .

Definitive Proxy Statement on Schedule 14A

Nominating and Governance Committee , page 8

7. Your disclosure concerning diversity on page 9 does not include a discussion of
how the Nominating and Governance Committee has implemented this policy  or
how the Committee assesses its effectiveness. Please revise your disclosure to
include this information. We refer you to Item 407(c)(2)(vi) of Regulation S -K.

Election of Directors, page 17

8. Please identify  the specific experience, qualifications, attributes or skills that led
to the conclusion that each person should serve as a director as required by Item
401(e) of Regulation S -K.  Please note that your discussion on page 8 is not
sufficient as the item requires a discussion of each individual’s experience,
qualifications, attributes or skills, as opposed to a discussion of the board
members’ collective experience, qualifications, at tributes or skills.

Compensation Discussion & Analysis, page 22

9.  We note your discussion of the establishmen t of the bonus pool on page 27.
Please disclose the amount of the bonus pool and  confirm that each individual’s
goals were used to determine the portion of the pool awarded to each individual as
a bonus.

10. Please revise the discussion of the annual cash bonus awards to discuss the
Committee’s overall assessment of each named exe cutive officer’s performance
based on the individual goals identified.  Your discussion should address the
extent to which the Committee believes that each named executive officer,
achieved, over achieved or under achieved his or her goals, any significant  factors
considered in making the assessment and the percentage of the bonus pool
awarded to each named executive officer.

* * * *

 Please provide us the information requested  within 10 business days or tell us
when you will provide us with a response.  Please furnish a cover letter with your response
that keys your response to our comments.  Detailed cover letters greatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

Conan R. Deady
Idexx Laboratories, Inc.
May 20, 2010
Page 4

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure i n the filing to be certain that the filing include 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 a re 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 your letter, a
statement from the company acknowledging that:

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

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respec t to the filing;
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 Enforceme nt has access to all
information you provide to the staff of the Division of Corporation Finance in our review
of your filing or in response to our comments on your filing.

Please contact Scot Foley  at (202) 551 -3383, Suzanne Hayes, Branch Chief, at
(202) 551 -3675 or me at (202) 551 -3715 with any questions.

        Sincerely,

        Jeffrey P. Riedler
        Assistant Director

Mail Stop 6010
  February 12, 2008
 Conan R. Deady
Corporate Vice President and General Counsel
IDEXX Laboratories, Inc. One IDEXX Drive Westbrook, ME 04092
Re: IDEXX Laboratories, Inc.  Definitive Proxy Statement
Filed March 29, 2007
 File No. 000-19271
 Dear Mr. Deady:
We have completed our review of your executive compensation and related
disclosure and have no further comments at this time.
Please note that the company is responsib le for the adequacy and accuracy of the
disclosure in its filing.  We  are not approving any proposed  disclosure you may have
included in your response lette r or any disclosure you include in your future filings in
response to our comments.
If you have any further questions regardi ng our review of your filing, please call
me at (202) 551-3635.          S i n c e r e l y ,             T i m  B u c h m i l l e r          S e n i o r  A t t o r n e y

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IDEXX Response to SEC letter of 01142008

February 8, 2008

Mr. Tim Buchmiller

Senior Attorney

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

            Re:

            IDEXX Laboratories, Inc.

            Definitive Proxy Statement filed March 29, 2007

            File No. 000-19271

Dear Mr. Buchmiller:

Please see our response below to your letter dated January 14, 2008. Our response is preceded by a reproduction of the comment contained in your letter.

In connection with our response, we acknowledge that:

            •

            We, the Company, are responsible for the adequacy and accuracy of the disclosure in the filing;

            •

            Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

            •

            We, 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.

Comment:

We have reviewed your response to comment 8 and are unable to concur in your conclusion that an 8% increase in base salary, an increase which is significantly higher than the consumer price index for the relevant period, is not material.  In your future filings, please provide discussion and analysis as to why any element of compensation paid or awarded to any named executive officer was materially increased or decreased.

Response:

We do not believe the materiality of a change in compensation can be assessed based on any single factor.  Rather, consistent with staff guidance in other contexts where SEC rules do

Mr. Tim Buchmiller

United States Securities and Exchange Commission

February 8, 2008

Page 2

not establish a bright-line test of materiality, we believe that the materiality of a change in compensation must be assessed by considering all relevant quantitative and qualitative factors and considering whether a particular change would be viewed by the reasonable investor as having significantly altered the "total mix" of information made available.

In particular, we do not agree that the materiality of a change in compensation can be assessed solely by a comparison to the consumer price index.  Changes in the CPI are not a factor explicitly considered by the company’s compensation committee in setting compensation.  Moreover, we do not believe changes in the CPI are generally used as a significant factor by public companies in setting executive compensation or that investors generally view the relationship of changes in executive compensation to changes in CPI as a material factor in their assessment of the reasonableness of executive compensation.

Nevertheless, in light of the staff’s comment, in the future, beginning with our 2008 proxy statement, we will take the CPI into account as part of our materiality analysis.

With respect to our 2007 proxy statement, we note that the salary increase that is the subject of the staff’s comment was an increase relating to fiscal 2007.  We do not believe that this increase is material to an understanding of NEO compensation for fiscal 2006 (the fiscal year that is the primary subject of the CD&A included in our 2007 proxy statement) because (1) no amounts relating to the 2007 change in base salary are included in the summary compensation table for fiscal 2006 and (2) the 2007 change in base salary does not represent a change in compensation arrangements from fiscal 2006 that could affect a fair understanding of NEO compensation for fiscal 2006.

While the company will likely elect to discuss the February 2007 change in the CEO’s base salary as part of its CD&A for the year ended December 31, 2007, for the reasons set forth below, the company does not believe the change in base pay is material in amount or significance.  Please note that the company plans to reassess its conclusion regarding materiality after the Board takes action with respect to discretionary bonuses for the year ended December 31, 2007, which has not yet occurred.

            •

            The increase is not significant to the company’s results of operations or financial position. For example, $50,000 represents less than 0.1%  of the company’s net income for 2006 and 2007, and less than 0.02% of the company’s current assets at year end 2006 and 2007.

            •

            The increase in base salary represents a small dollar amount and percentage increase in the CEO’s total compensation and total cash compensation for fiscal 2006.  A $50,000 increase in base pay represents approximately 2% of the CEO’s total compensation for fiscal 2006 and approximately 4% of the CEO’s total cash compensation for fiscal 2006.

            •

            The increase in base salary did not represent a change in compensation philosophy, objectives or approach.

Mr. Tim Buchmiller

United States Securities and Exchange Commission

February 8, 2008

Page 3

            •

            The percentage increase in base salary is consistent with the level of increases awarded to the company’s other executive officers for 2007.

            •

            The 8% increase in base salary was at a rate less than double the rate of inflation, as measured by the CPI, that prevailed during 2007.  As announced by the Bureau of Labor Statistics on January 16, 2008, the CPI for All Urban Consumers for December 2007 was 4.1% higher than in December 2006 and the CPI for All Urban Consumers in the Northeast in cities with a population between 50,000 and 1,500,000 (which includes Portland, Maine) was 4.4% higher in December 2007 than in December 2006.  Accordingly, only approximately half of the change in base salary (or less than $25,000) represented a true increase in base pay as measured by the CPI.  (We note that the corresponding CPI indices at February 2007 were lower.  However, in assessing materiality for purposes of preparing this year’s CD&A, we believe it is appropriate to
consider the CPI indices for full-year 2007.)

            •

            Since the CEO’s base salary is under $1,000,000, the change in his base salary does not automatically result in any loss of deductibility under Code Section 162(m).  In deciding the amount of bonus to be paid to the CEO under the company’s discretionary bonus program, the compensation committee will be advised with respect to the amount of that bonus that will be non-deductible under Section 162(m) and will include appropriate discussion of that fact in the proxy statement to the extent it is material.

            •

            While the increase in base salary increases the CEO’s target bonus under the company’s annual discretionary cash bonus, since the amount of that bonus is completely discretionary, it does not have a direct or automatic impact on any payments to be made under the bonus plan.  Also, the increase in base salary does not impact the CEO’s equity awards or other compensatory payments, other than potential payouts upon termination (which will be quantified in the tables the company includes in its proxy statement).

If you have any questions regarding the foregoing, please do not hesitate to contact me at (207) 556-4920.

Sincerely,

Conan R. Deady

Corporate Vice President and General Counsel

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IDEXX Respnse dated 01252008 to SEC letter dated 01142008

January 25, 2008

Mr. Tim Buchmiller

Senior Attorney

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

            Re:

            IDEXX Laboratories, Inc.

            Definitive Proxy Statement filed March 29, 2007

            File No. 000-19271

Dear Mr. Buchmiller:

I am writing to advise that we will respond to your letter dated January 14, 2008 by no later than February 11, 2008.

If you have any questions regarding the foregoing, please do not hesitate to contact me at (207) 556-4920.

Sincerely,

Conan R. Deady

Corporate Vice President and General Counsel

Mail Stop 6010
  August 21, 2007

Jonathan W. Ayers
Chief Executive Officer IDEXX Laboratories, Inc. One IDEXX Drive Westbrook, ME 04092
Re: IDEXX Laboratories, Inc.  Definitive Proxy Statement
Filed March 29, 2007
 File No. 000-19271
 Dear Mr. Ayers:
We have limited our review of your definitive proxy statement to your executive
compensation and other related disclosure a nd have the following comments.  Our review
of your filing is part of the Division’s focused review of executive compensation disclosure.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call me at the telephone  number listed at the end of this letter.
  In some comments we have asked you to provide us with additional information so we may better understand your disclosure.  Pl ease do so within the time frame set forth
below.  You should comply with the remain ing comments in all future filings, as
applicable.  Please confirm in writing that you will do so and also explain to us how you
intend to comply.  Please unders tand that after ou r review of all of your responses, we
may raise additional comments.   If you disagree with any of these commen ts, we will consider your explanation as
to why our comment is inapplicable or a revisi on is unnecessary.  Please be as detailed as
necessary in your explanation.

IDEXX Laboratories, Inc.
August 21, 2007 Page 2   Compensation Discussion and Analysis, page 22

 1. In an appropriate location in your Co mpensation Discussion and Analysis, please
disclose whether the Compensation Committ ee can exercise disc retion either to
award compensation absent attainment of th e relevant corporate or personal goals
or objectives, or to reduce or increase th e size of any award or payout.  Refer to
Item 402(b)(2)(vi) of Regulation S-K.
 Benchmarking, page 23

 2. Given that you benchmark the compensa tion of your named executive officers,
please expand your disclosure to addr ess how you target each element of
compensation against the comparator companies.  Please specify how each element of compensation relates to th e data you have analyzed from the
comparator companies and include a disc ussion of where you target each element
of compensation against the peer companies and where actual payments fell within the targeted parameters.  To th e extent actual compensation was outside a
targeted percentile range, please explain why.
 Annual cash bonus, page 24

 3. We note that the amount of the bonus actually paid to each executive officer
depends on achieving overall corporate pe rformance goals and individual annual
performance goals.  You have not, however, provided a quantitative or qualitative discussion of the goals to be achieved in order for named executive officers to earn their respective incen tive compensation.  Please disclose the specific
corporate and individual obj ectives each named executive officer was required to
achieve in order to receive the annual bonus granted.  To the extent you believe
that disclosure of the information would result in competitive harm such that the information could be excluded under Instruct ion 4 to Item 402(b), please provide
us with a detailed explana tion supporting your conclusion.   To the extent that it is
appropriate to omit specific targets or pe rformance objectives, you are required to
provide appropriate disclosure pursuant to Instruction 4 to Item 402(b) of
Regulation S-K.  Refer also to Questi on 3.04 of the Item 402 of Regulation S-K
Interpretations available on our website at www.sec.gov
.  In discussing how
difficult or likely it will be for the registra nt to achieve the target levels or other
factors, you should provide as much deta il as necessary without disclosing
information that poses a reasonable risk of competitive harm.
 Equity Awards, page 25

 4. You disclose that the target value of the equity awards is intended to give effect to your philosophy that equity aw ards should have the potenti al to raise an officer's

IDEXX Laboratories, Inc.
August 21, 2007 Page 3
total compensation above the median of the peer group if the company performs
better than its comparable companies.   Please indicate what metrics the
Compensation Committee utilizes in assessing whether your company has
performed better than the rele vant peer companies.  Also discuss and analyze how
the relative performance of your company against the peer gr oup resulted in the
granting of equity awards that on aver age were 109% of the target amount.
 5. You disclose that the "size of annua l dollar award value is a subjective
determination based on the anticipated cont ribution of the executive officer to the
long-term value of the company."  Pleas e clarify the factors the Compensation
Committee took into consideration in  making these awards and how the
Compensation Committee used those factors in setting the actual amounts of the award values.
 6. Discuss how the determination is made as to when your equity awards are granted.  See Item 402(b)(2)(iv) of Regulation S-K.
 Change in Control Agreements, page 26

 7. We note from the last bullet point that your executives would be required to enter
into new non-compete agreements as a condition of receiving compensation and benefits under the change in  control agreements.  As required by Item 402(j)(4) of
Regulation S-K, please disclose the cont emplated duration of such non-compete
agreements and provisions regarding waiver of breach of such agreements.
 Chief Executive Officer Compensation, page 27

 8. We note that you increased Mr. Ayers ba se salary by 8% in February 2007.
Please discuss the factors considered in the decision to increase this element of
compensation.  Refer to Item 402(b)(2)(ix) of Regulation S-K.
 9. We note your disclosure that the extraord inary grant to Mr. Ayers was appropriate
to maintain the competitiveness of his total compensation package.  Please discuss and analyze with greater specific ity how the Compensation Committee
determined that Mr. Ayers compensation package was deficient from a competitive standpoint, and how the form and amount of this award would make
up for those deficiencies.
 Potential Change in Control Payments, page 36

 10. We note that the change in control pa yments for your chief executive officer
amount to three times his average salar y, bonus and benefits, and for all other
executive officers the change in control payments amount to two years of each

IDEXX Laboratories, Inc. August 21, 2007 Page 4
such officer's respective payments and benefits.  Please discuss and analyze how these amounts were negotiated and how and why the specified periods were
agreed to by the company and why the pe riods vary among the officers.  Refer to
Item 402(b)(1)(v) of Regulation S-K.
  Please respond to our comments by September 21, 2007, or tell us by that time when you will provide us with a response.
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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy  of the disclosures they have made.
  When you respond 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 filing;

• staff comments or changes to disclo sure in response to comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and
 • the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to comments.

Please contact me at (202) 551-3635 with any questions.

Sincerely,    Tim Buchmiller Senior Attorney

Mail Stop 6010

 January 14, 2008

Conan R. Deady
Corporate Vice President and General Counsel IDEXX Laboratories, Inc. One IDEXX Drive Westbrook, ME 04092
Re: IDEXX Laboratories, Inc.  Definitive Proxy Statement
Filed March 29, 2007
 File No. 000-19271
 Dear Mr. Deady:
We have reviewed your response letter  dated September 21, 2007 and have the
following comments.  Please respond to our  comments by January 28, 2008 or tell us by
that time when you will provide us with a re sponse.  If the comments request revised
disclosure in future filings, please confir m in writing that you will comply with the
comments in your future filings and also ex plain to us how you intend to comply.  We
welcome any questions you may have about our comments or any other aspect of our review.  1. We have reviewed your response to comm ent 8 and are unable to concur in your
conclusion that an 8% increase in base sa lary, an increase which is significantly
higher than the consumer price index for th e relevant period, is not material.  In
your future filings, please provide discussion and analysis as to why any element of compensation paid or awarded to a ny named executive officer was materially
increased or decreased.

If you have any questions, pleas e contact me at (202) 551-3635.
         S i n c e r e l y ,             T i m  B u c h m i l l e r          S e n i o r  A t t o r n e y

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September 21, 2007

Mr. Tim Buchmiller

Senior Attorney

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

            Re:

            IDEXX Laboratories, Inc.

            Definitive Proxy Statement filed March 29, 2007

            File No. 000-19271

Dear Mr. Buchmiller:

Please see our responses below to your letter dated August 21, 2007. Each of our responses is preceded by a reproduction of the corresponding numbered Staff comments.

In connection with responding to your comments, we acknowledge that:

            •

            We, the Company, are responsible for the adequacy and accuracy of the disclosure in the filing;

            •

            Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

            •

            We, 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.

Compensation Discussion and Analysis, page 22

Comment:

            1.

            In an appropriate location in your Compensation Discussion and Analysis, please disclose whether the Compensation Committee can exercise discretion either to award compensation absent attainment of the relevant corporate or personal goals or objectives, or to reduce or increase the size of any award or payout. Refer to Item 402(b)(2)(vi) of Regulation S-K.

Mr. Tim Buchmiller

United States Securities and Exchange Commission

September 21, 2007

Page 2

Response:

The size of the annual bonuses paid by the Company to its executive officers is determined in the discretion of the Compensation Committee of the Board of Directors, as described in the Company’s 2007 proxy statement under “Compensation Discussion and Analysis – Elements of Compensation – Annual Cash Bonus.” While the Compensation Committee considers many factors in determining the size of the bonus to be paid to each executive officer, including the performance of the Company relative to its budget, the size of each bonus award is not tied directly to the achievement of any particular financial or other goal.  Since no particular award or payout is associated with the achievement of any particular performance goal, the determination of the Compensation Committee regarding award size does not involve the exercise of the kind of discretion described in Item
402(b)(2)(vi), which contemplates disclosure of the Compensation Committee’s discretion to deviate from the award that would otherwise result from the attainment or non-attainment of particular performance goals.

In future proxy statements, as applicable, beginning with the proxy statement for the Company’s 2008 annual meeting of shareholders, the Company will make clear that, while each executive officer has a target bonus potential associated with his or her position, the actual bonus paid is determined in the sole discretion of the Committee based on any factors it deems relevant.  In this disclosure the Company will also state that the award determined by the Committee may be greater than, equal to, or less than the target bonus for each executive officer, and may be awarded (in whole or in part) or not awarded without regard to whether the Company achieves any particular performance goal.

Benchmarking, page 23

Comment:

            2.

            Given that you benchmark the compensation of your named executive officers, please expand your disclosure to address how you target each element of compensation against the comparator companies.  Please specify how each element of compensation relates to the data you have analyzed from the comparator companies and include a discussion of where you target each element of compensation against the peer companies and where actual payments fell within the targeted parameters.  To the extent actual compensation was outside a targeted percentile range, please explain why.

Response:

In determining the total value of annual executive compensation (base salary, bonus potential, and equity award value) the Compensation Committee takes into consideration survey data related to general industry and to a defined group of peer companies, which are listed in “Compensation Discussion and Analysis - Compensation Philosophy – Benchmarking” on page 24 of the 2007 proxy statement. In evaluating these survey results, the Committee considers primarily the relationship of total compensation paid to the Company’s executive officers to the

Mr. Tim Buchmiller

United States Securities and Exchange Commission

September 21, 2007

Page 3

total compensation paid to similarly situated executives as represented in the survey data. The Company generally does not target any particular percentage of total compensation reflected in the survey data, although as described in the response to comment 4 below, the Committee did target the median total compensation of chief executive officers in the peer group when valuing the extraordinary stock option grant to the chief executive officer in 2007. Similarly, the Committee does not target individual elements of compensation paid to its executive officers to the individual elements paid to executives in the survey data. The relative value of each element of compensation paid to the Company’s executive officers is a function of the Company’s compensation philosophy, as described under “Compensation Discussion and Analysis – Compensation Philosophy.”

In future proxy statements, as applicable, beginning with the proxy statement for the Company’s 2008 annual meeting of shareholders, the Company will clarify how the Compensation Committee uses the survey data as described above.

Annual cash bonus, page 24

Comment:

            3.

            We note that the amount of the bonus actually paid to each executive officer depends on achieving overall corporate performance goals and individual annual performance goals.  You have not, however, provided a quantitative or qualitative discussion of the goals to be achieved in order for named executive officers to earn their respective incentive compensation. Please disclose the specific corporate and individual objectives each named executive officer was required to achieve in order to receive the annual bonus granted. To the extent you believe that disclosure of the information would result in competitive harm such that the information could be excluded under Instruction 4 to Item 402(b), please provide us with a detailed explanation supporting your conclusion. To the extent that it is appropriate to omit specific targets or performance objectives, you are
required to provide appropriate disclosure pursuant to Instruction 4 to Item 402(b) of Regulation S-K. Refer also to Question 3.04 of the Item 402 of Regulation S-K Interpretations available on our website at www.sec.gov. In discussing how difficult or likely it will be for the registrant to achieve the target levels or other factors, you should provide as much detail as necessary without disclosing information that poses a reasonable risk of competitive harm.

Response:

As discussed in the response to the Staff’s comment 1 above, the annual cash bonuses paid to the Company’s executive officers are determined in the discretion of the Compensation Committee. The Committee considers all factors that it deems relevant to evaluating an executive’s performance over the year.  Among the factors considered by the Committee are the executive’s performance against the individual goals established by the executive and his or her supervisor at the beginning of the year and the Company’s performance against the budget approved by the Board of Directors at the beginning of the year. Neither individual goals nor the Company’s budget are established as a framework for determining the executive’s year-end

Mr. Tim Buchmiller

United States Securities and Exchange Commission

September 21, 2007

Page 4

bonus. Rather, individual goals are part of the Company’s annual performance management process, which is applicable to all management employees of the Company, and the budget is prepared and approved as a part of the normal management of the Company. There is no pre-defined link between the achievement of individual goals or budget targets and the percentage of target bonus that the executive ultimately receives. The Committee may also consider other factors related to the Company’s performance during the year that are not reflected in either the budget or any executive’s annual performance goals, and indeed may not be foreseeable at the beginning the year. The reasons for the Company’s determination not to utilize a formulaic approach to the payment of annual bonuses are described in the second paragraph on page 25 of the 2007 proxy statement.

Because (i) executive officer’s annual goals are established for performance management purposes and not to set criteria for the payment of the target bonus or any percentage of the target bonus, (ii) budgets are established as part of the prudent financial management of the Company and not to set such criteria, (iii)  the Compensation Committee considers achievement of these goals together with such other factors as it deems relevant in determining annual bonuses, and (iv) the Committee does not give any particular weight to any particular factor but rather makes a subjective bonus determination based on all factors, the Company does not believe that each executive’s annual performance goals or the budget targets are the kind of targets that are required to be disclosed under Item 402(b)(2) of Regulation S-K.

In future proxy statements, as applicable, beginning with the proxy statement for the 2008 annual meeting of shareholders, the Company will provide disclosure clarifying that the factors considered by the Compensation Committee include performance against goals established for performance management purposes and a budget established for financial management purposes, and that such goals are not linked to the payment of any particular percentage of annual bonus target. The disclosure will clarify that the annual bonus awarded by the Committee is a completely subjective determination based on all factors deemed relevant by the Committee.

Equity Awards, page 25

Comment:

            4.

            You disclose that the target value of the equity awards is intended to give effect to your philosophy that equity awards should have the potential to raise an officer’s total compensation above the  median of the peer group if the company performs better than its comparable companies. Please indicate what metrics the Compensation Committee utilizes in assessing whether your company has performed better than the relevant peer companies.  Also discuss and analyze how the relative performance of your company against the peer group resulted in the granting of equity awards that on average were 109% of the target amount.

Mr. Tim Buchmiller

United States Securities and Exchange Commission

September 21, 2007

Page 5

Response:

The Company does not set target equity award levels, or grant equity awards, based upon the performance of the Company relative to peer group companies, and therefore does not track any metrics relating to comparative performance. The Company’s philosophy is that equity awards should be of a size such that if the Company’s share price appreciation is materially greater than that of the peer companies, then the value actually derived over time by the recipient of the award (as opposed to the Black-Scholes award value at the time of the award) should permit the recipient to realize total compensation over the longer term that is above the median for the peer group. However, the Company does not have any formula for targeting the size of equity awards to give effect to this philosophy, nor does the Company track any metrics that permit it to determine in hindsight whether the
Company’s share price has in fact out-performed the peer group and whether executive officers have in fact realized total compensation above the median as a result of the value actually derived from equity awards.

In future proxy statements, as applicable, beginning with the proxy statement for the 2008 annual meeting of shareholders, to the extent this philosophy continues to be a relevant factor in determining equity awards, the Company will clarify in its disclosure about this philosophy that equity award grants are not based on any metrics related to the Company’s performance relative to the performance of companies within the peer group.

            Comment:

            5.

            You disclose that the “size of annual dollar award value is a subjective determination based on the anticipated contribution of the executive officer to the long-term value of the company.” Please clarify the factors the Compensation Committee took into consideration in making these awards and how the Compensation Committee used those factors in setting the actual amounts of the award values.

Response:

In setting actual equity award values, the Committee considers the executive officer’s job scope relative to other executive officers, the executive officer’s long-term leadership potential, the size of prior awards to the executive officer and the value already derived from those awards, and internal pay equity considerations. In future proxy statements, as applicable, beginning with the proxy statement for the 2008 annual meeting of shareholders, the Company will provide additional disclosure discussing the specific factors, including where relevant those described in the preceding sentence, considered by the Compensation Committee in determining the size of the annual equity award grants made to executive officers.

Comment:

            6.

            Discuss how the determination is made as to when your equity awards are granted. See Item 402(b)(2)(iv) of Regulation S-K.

Mr. Tim Buchmiller

United States Securities and Exchange Commission

September 21, 2007

Page 6

Response:

The Company discloses its practices regarding the timing of equity award grants in the second to last paragraph on page 23 of the 2007 proxy statement. The timing of equity award grants is determined by an equity award grant policy that was adopted by the Board of Directors.  This policy provides for fixed award dates that are, to the extent possible, tied to Compensation Committee meetings and occur outside of the quarterly blackout periods under the Company’s trading policies during which officers, directors, and certain other employees are precluded from trading Company shares. Most equity awards, including all annual awards to executive officers, are made on February 14 of each year, which shortly follows both the February Compensation Committee meeting at which prior year bonuses and current year salary determinations are made, and the Company’s earnings announcement for the
fourth quarter of the preceding year, which generally occurs in the last week of January.

In future proxy statements, as applicable, beginning with the proxy statement for the 2008 annual meeting of shareholders, the Company will enhance this disclosure to provide further details regarding this policy.

Change in Control Agreements, page 26

Comment:

            7.

            We note from the last bullet point that your executives would be required to enter into new non-compete agreements as a condition of receiving compensation and benefits under the change in control agreements. As required by Item 402(j)(4) of Regulation S-K, please disclose the contemplated duration of such non-compete agreements and provisions regarding waiver of breach of such agreements.

Response:

The duration of the referenced non-compete obligation would be two years and there are no provisio

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                     July 17, 2007
Ms. Merilee Raines
Corporate Vice President and Chief Financial Officer IDEXX Laboratories, Inc. One IDEXX Drive  Westbrook, Maine   04092

Re: IDEXX Laboratories, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2006   Filed on March 1, 2007
Form 10-Q for Fiscal Quarter Ended March 31, 2007  Filed on May 2, 2007
 File No. 000-19271

Dear Ms.  Raines:

We have completed our review of your Fo rms 10-K and 10-Q and have no further
comments at this time.           S i n c e r e l y ,             J o e l  P a r k e r          A c c o u n t i n g  B r a n c h  C h i e f

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IDEXX Response to SEC July 16, 2007

July 16, 2007

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, 2006, Filed on March 1, 2007

            Form 10-Q for Fiscal Quarter Ended March 31, 2007, Filed on May 2, 2007

            File No. 000-19271

Dear Mr. Rosenberg:

We are providing the following responses pursuant to the comments provided by Ms. Ibolya Ignat, Staff Accountant of the Division of Corporate Finance of the Securities and Exchange Commission (“SEC”), during a telephone call on Thursday, July 12, 2007 regarding your review of the above referenced Forms 10-K and 10-Q filed by IDEXX and our prior response dated June 6, 2007.

In connection with responding to your comments, we acknowledge that:

            •

            We, the Company, are 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 filing; and

            •

            We, 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.

SEC Comment (A):

Regarding your response to prior comment #2, confirm that you will provide, in future filings, a summary of changes in accrued customer programs liabilities that is similar to the table provided on page 10 of your response letter dated June 6, 2007.

Mr. Jim B. Rosenberg

United States Securities and Exchange Commission

July 16, 2007

Page 2

Response:

We confirm that we will include a similar disclosure of the changes in accrued customer programs liabilities in future periodic filings with the SEC, beginning with our next periodic filing on Form 10-Q for the quarterly period ended June 30, 2007, in the Critical Accounting Policies and Estimates section of Management’s Discussion and Analysis of Financial Condition and Results of Operations.

SEC Comment (B):

Regarding your response to prior comment #3, confirm that you will provide, in future filings, a disclosure of your deferred revenue policy that indicates your use of a systematic method to recognize revenue that has been deferred, similar to your response to prior comment #3 on page 11 of your response letter dated June 6, 2007.

Response:

We confirm that we will include a similar disclosure of our deferred revenue policy that indicates our use of a systematic method to recognize revenue that has been deferred. We will include this expanded description in the summary of significant accounting policies in the notes to consolidated financial statements in future periodic filings with the SEC, beginning with our next periodic filing on Form 10-Q for the quarterly period ended June 30, 2007.

If you have any questions regarding the foregoing, please do not hesitate to contact me at (207) 556-4446.

Sincerely,

/s/ Merilee Raines

Corporate Vice President & Chief Financial Officer

CORRESP
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IDEXX response to SEC June 6, 2007

June 6, 2007

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, 2006, Filed on March 1, 2007

            Form 10-Q for Fiscal Quarter Ended March 31, 2007, Filed on May 2, 2007

            File No. 000-19271

Dear Mr. Rosenberg:

Please see our responses below to your letter dated May 22, 2007. Each of our responses is preceded by a reproduction of the corresponding numbered Staff comments.

In connection with responding to your comments, we acknowledge that:

            •

            We, the Company, are 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 filing; and

            •

            We, 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.

Form 10-K December 31, 2006

Item 7.  Management’s Discussion and Analyses of Financial Condition and Results of Operations, page 20

Comment:

            1.

            The company reiterated here the policy notes included in the financial statements.  Critical Accounting Policies should supplement, not duplicate, the accounting policies disclosed in the notes to the financial statements.  Please provide us in a disclosure-type format the company’s analysis of the judgments and uncertainties involved in applying these accounting principles at a given time, and the potential impact on your financial statements of the

Mr. Jim B. Rosenberg

United States Securities and Exchange Commission

June 6, 2007

Page 2

variability that is reasonably likely to result from their application over time.  Disclosures explaining the likelihood that any materially different amounts would be reported under different conditions, using different assumptions is consistent with the objective of Management’s Discussion and Analysis.  See Release 33-8350.

Response:

We acknowledge the Commission guidance regarding the presentation of critical accounting policies. Below is a revised disclosure regarding our critical accounting policies as of December 31, 2006. We will include a similar expanded disclosure of our critical accounting policies in our periodic filings with the SEC for 2007, beginning with the Form 10-Q for the quarterly period ending June 30, 2007.

CRITICAL ACCOUNTING POLICIES AND ESTIMATES

The discussion and analysis of our financial condition and results of operations is based upon our consolidated financial statements, which have been prepared in accordance with accounting principles generally accepted in the U.S. The preparation of these financial statements requires us to make estimates and judgments that affect the reported amounts of assets, liabilities, revenues and expenses, and related disclosure of contingent assets and liabilities. On an ongoing basis, we evaluate our estimates. We base our estimates on historical experience and on various other assumptions that we believe to be reasonable under the circumstances, the results of which form the basis for making judgments about the carrying values of assets and liabilities that are not readily apparent from other sources. Actual results may differ from these estimates. Note 2 to the consolidated
financial statements for the year ended December 31, 2006 included in our Annual Report on Form 10-K for the year ended December 31, 2006 describes the significant accounting policies used in preparation of these financial statements.

We believe the following critical accounting estimates and assumptions may have a material impact on reported financial condition and operating performance and involve significant levels of judgment to account for highly uncertain matters or are susceptible to significant change.

Revenue Recognition

Customer Programs. We record estimated reductions to revenue in connection with customer marketing programs and incentive offerings, which may give customers credits or award points. Award points may be applied to trade receivables owed to us and/or toward future purchases of our products or services. We establish accruals for estimated revenue reductions attributable to customer programs and incentive offerings for each program based on numerous factors, including:

            •

            forecasted purchasing patterns of those enrolled in the program based on historical experience with similar programs, current sales trends and market analyses;

            •

            inventory levels of eligible products in the distribution channel; and

            •

            estimated number of participants that will ultimately reach volume purchase thresholds.

Revenue reductions are recorded quarterly based on issuance of credits, points earned but not yet issued, and estimates of credits and points to be earned in the future based on current revenue. In our analysis, we utilize data supplied from distributors and collected in-house that details the volume of qualifying products purchased as well as price paid per clinic (“practice-level sales data”).

Mr. Jim B. Rosenberg

United States Securities and Exchange Commission

June 6, 2007

Page 3

Our two most significant customer programs are Practice Developer®   and SNAP up the SavingsTM (“SUTS”).  For the years ended December 31, 2006 and 2005 we recorded revenue reductions of $5.1 million and $4.8 million, respectively, related to our Practice Developer® program and $4.9 million and $5.1 million, respectively, related to our SUTS program. As of December 31, 2006 and 2005 the accrued revenue reductions were $10.4 million and $7.1million, respectively, for the Practice Developer®program and $1.4 million for both years for the SUTS program.  The income statement impact of year-to-year changes in estimates related to these programs was not material in either year.

Our Practice Developer® program is a Companion Animal Group awards program that permits customers to earn points by purchasing quarterly minimums in certain product and service categories, including IDEXX Reference Laboratories, VetTest® slides, LaserCyte® tubes, Feline SNAP® tests and Canine SNAP® tests.  Points may then be applied against the purchase price for IDEXX products and services purchased in the future.  SUTS is our volume incentive program for selected SNAP® tests that provides customers with benefits in the form of (1) discounts off invoice at the time of purchase and (2) points under the Practice Developer® program awarded at the end of the SUTS program year (August 30) based on total purchase volume of qualified products during the year.

For the Practice Developer program, we reduce revenue assuming all points granted will result in future credits because the historical forfeitures have been de minimis. The accrued revenue reduction is calculated each quarter based on sales to end users during the quarter by either us or our distributors and on our estimate of future points to be issued upon sale of applicable product inventories held by distributors at the quarter end. On November 30 of each year, unused points granted before January 1 of the prior year expire and are accounted for as a favorable change in estimate.

Under the SUTS program, the discount ultimately received by a customer will depend on the volume of products purchased by the customer, either from us or our distributors, over the entire program period.  Because at any time during the period we cannot be certain what discount level each customer ultimately will be entitled to, at the beginning of the period we develop a program model that forecasts a per test discount for all tests sold over the program period based on program enrollee purchasing patterns, historical experience with similar programs, current sales trends, and marketing analysis.  The per test discount is adjusted quarterly during the program year based on our experience with the program and finalized when the program year ends in August.  The accrued revenue reduction is calculated each quarter by applying the applicable per test discount to sales to end
users during the quarter by either us or our distributors. The accrued revenue reduction also includes our estimate of future points to be issued upon sale of applicable product inventories held by distributors at the quarter end.

If the per test factor used to determine the revenue reduction under the SUTS program were to increase or decrease by 10% per test, we would be required to further reduce revenue or increase revenue, as the case may be, by $0.2 million.

Doubtful Accounts.  We recognize revenue only in those situations where collection from the customer is reasonably assured. We maintain allowances for doubtful accounts for estimated losses resulting from the inability of our customers to make required payments. We base our estimates on detailed analysis of specific customer situations and a percentage of our accounts receivable by aging category. If the financial condition of our customers were to deteriorate, resulting in an impairment of their ability to make payments, additional allowances might be required. Account balances are charged off against the allowance when we believe it is probable the receivable will not be recovered.  Write-offs of customer accounts for the years ended December 31, 2005 and 2006 were $0.4 million and $0.5 million, respectively.

Inventory Valuation

We write down inventory for estimated obsolescence when warranted by estimates of future demand and market conditions. If actual market conditions are less favorable than those we estimated,

Mr. Jim B. Rosenberg

United States Securities and Exchange Commission

June 6, 2007

Page 4

additional inventory write-downs may be required, which would have a negative effect on results of operations. Certain major components of inventory for which we have made critical valuation judgments are discussed in more detail below.

LaserCyte® Hematology Analyzer.  At December 31, 2006, $1.7 million of inventory associated with our LaserCyte® hematology instrument required rework before it could be used to manufacture finished goods, which was net of $0.9 million of write-downs for inventory estimated to be obsolete. We determined obsolescence based on our estimate of the costs to rework inventory and the probability of success, primarily based on historical experience. We expect to fully realize our net investment in inventory. However, if we are unsuccessful reworking this inventory, if we revise our judgment of our ability to successfully rework inventory due to new experience in reworking this inventory, or if we alter the design of this product, we may be required to write off some or all of the remaining associated inventory.

Nitazoxanide.  At December 31, 2006, our inventories included $9.3 million of inventory associated with Navigator®, our nitazoxanide product for the treatment of equine protozoal myeloencephalitis. This inventory consisted of $0.2 million of finished goods and $9.1 million of active ingredient and other raw materials. We have an agreement with our supplier of nitazoxanide under which the supplier agreed until 2017 to replace any expiring inventory of nitazoxanide with longer-dated material. We believe that this agreement has substantially mitigated the risk that we would be required to write down nitazoxanide inventory due to its anticipated expiration prior to sale. However, if actual market conditions or our market share through 2025 are less than we estimate, we may be required to write off some of the associated inventory. For
example, if we sell approximately 50% fewer units through 2025 than we estimate, we would have approximately $5 million of excess inventory that we would be required to write off.

Valuation of Goodwill and Other Intangible Assets

A significant portion of the purchase prices for acquired businesses is assigned to intangible assets. Intangible assets other than goodwill are initially valued at the lesser of fair value or, if applicable, fair value proportionately reduced by the excess of the fair value of acquired net assets over the purchase price (collectively, “fair value”) of the acquired business. If a market value is not readily available, the fair value of the intangible asset is estimated based on discounted cash flows using market participant assumptions, which are assumptions that are not specific to IDEXX. The selection of appropriate valuation methodologies and the estimation of discounted cash flows require significant assumptions about the timing and amounts of future cash flows, risks, appropriate discount rates, and the useful lives of intangible assets. When deemed
appropriate by management, we utilize independent valuation experts to advise and assist us in allocating the purchase prices for acquired businesses to the fair values of the identified intangible assets and in determining appropriate amortization methods and periods for those intangible assets. Goodwill is initially valued based on the excess of the purchase price of a business combination over the fair values of acquired net assets.

We assess goodwill for impairment annually and whenever events or circumstances indicate an impairment may exist, in accordance with Statement of Financial Accounting Standards (“SFAS”) No. 142, “Goodwill and Other Intangible Assets” (“SFAS No. 142”). For impairment testing, the fair values of the reporting units that include goodwill are estimated using a discounted cash flow approach. The cash flows used contain our best estimates, using appropriate and customary assumptions and projections at the time. No impairments were identified as a result of the annual or event-driven reviews during the years ended December 31, 2006, 2005 or 2004.

Changes in forecast cash flows or the discount rate would affect the estimated fair values of reporting units and could result in a goodwill impairment charge in a future period. However, a 25% decrease in the current estimated fair value of any of our reporting units would not result in a goodwill impairment charge for any of our reporting units that include goodwill. Because our pharmaceutical

Mr. Jim B. Rosenberg

United States Securities and Exchange Commission

June 6, 2007

Page 5

business is still substantially in an investment stage, the determination of the fair value of this business unit requires significant assumptions about the timing and amounts of the unit’s future cash flows, including assumptions about the markets for our products and proprietary technologies, the future success of research and development activities, the attainment and timing of regulatory approvals to manufacture and sell new products, the introduction and success of competitive products by other market participants, and other business risks. We believe that the goodwill attributable to our pharmaceutical business of $13.7 million was not impaired at December 31, 2006. However, significant changes in our assumptions and estimates due to new information, or actual results that are below our expectations, could result in an impairment in the future of some or all of the goodwill
attributable to our pharmaceutical products business.

We assess the realizability of intangible assets other than goodwill whenever events or changes in circumstances indicate that the carrying value may not be recoverable in accordance with SFAS No. 144, “Accounting for the Impairment or Disposal of Long-Lived Assets” (“SFAS No. 144”). If an impairment review is triggered, we evaluate the carrying value of intangible assets based on estimated undiscounted

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                  May 22, 2007
Ms. Merilee Raines
Corporate Vice President and Chief Financial Officer IDEXX Laboratories, Inc. One IDEXX Drive  Westbrook, Maine   04092

Re: IDEXX Laboratories, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2006   Filed on March 1, 2007
Form 10-Q for Fiscal Quarter Ended March 31, 2007  Filed on May 2, 2007
 File No. 000-19271
Dear Ms.  Raines:

We have reviewed your filing and have the following comments.  We have
limited our review of your filing to the issues we have addressed in our comments.  In our
comments, we ask you to provide us with in formation so we may better understand your
disclosure.  Please be as deta iled as necessary in your expl anation.  After reviewing this
information, we may raise additional comments.   Please understand that the purpose of our re view 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.
 Item 7.  Management’s Discussion and Analys es of Financial Condition and Results of
Operations, page 20
 1. The company reiterated here the policy notes  included in the financial statements.
Critical Accounting Polices should suppl ement, not duplicate, the accounting
policies disclosed in the notes to the fina ncial statements.  Please provide us in a
disclosure-type format the company's anal ysis of the judgments and uncertainties
involved in applying these accounting principl es at a given time, and the potential

Ms. Merilee Raines
IDEXX Laboratories, Inc. May 22, 2007 Page 2
 impact on your financial statements of the variability that is reasonably likely to
result from their applicati on over time.  Disclosures expl aining the likelihood that
any materially different amounts would be reported under different conditions,
using different assumptions is consiste nt with the objective of Management’s
Discussion and Analysis.  See Release 33-8350.
 Revenue Recognition, pages 24-25

 2. Your disclosures related to estimates of items that reduce gross revenue such as
customer credits, award points, trade- in rights and other discounts could be
improved as follows:

• Disclose the nature and amount of each accrual at the balance sheet date.
• Disclose the factors that you consider in  estimating each accrual such as levels
of inventory in the distribution channel,  estimated remaining shelf life, price
changes from competitors and others as applicable.
• Disclose the major terms of material arrangements/agreements
• Disclose your policy with respect to  determining when a receivable is
recorded as a bad debt and ultimately written off.
• Disclose a roll forward of the liab ility for each estimate for each period
presented showing the following:
o Beginning balance,
o Current provision related to sales made in current period,
o Current provision related to sales made in prior periods,
o Actual returns or credits in current period related to sales made in
current period,
o Actual returns or credits in current period related to sales made in prior
periods, and
o Ending balance.
• In your discussion of results of opera tions for the period to period revenue
comparisons, discuss the amount of and reason for fluctuations for each type
of reduction of gross revenue (i.e. cust omer credits, award points, trade-in
rights and other discounts) including the e ffect that changes in your estimates
of these items had on your revenues a nd operations.  Provide your response in
a disclosure-type format.
 3. Please clarify your deferred revenue policy to indicate whether and to what extent
and how you use any type of systematic method to recognize revenue that has
been deferred.

Ms. Merilee Raines
IDEXX Laboratories, Inc. May 22, 2007 Page 3
 Liquidity and Capital Resources, page 39

 Contractual Obligations Table. Page 42

 4. You did not include interest payable on long-term debt in the contractual
obligation table, and it would appear that  these liabilities represent future legal
obligations.  Due to the signi ficant nature of these liab ilities to your business we
believe their inclusion in the contractua l obligation table wi ll provide investors
increased disclosure of your liquidity .  The purpose of Financial Reporting
Release 67 is to obtain enhanced disclosu re concerning a regist rant’s contractual
payment obligations and the exclusion of ordinary course items would be
inconsistent with the objec tive of the Item 303(a)(5) of Regulation S-K.  Based on
the above factors, please pr ovide us in disclosure-type  format revisions to your
contractual obligation table to include interest payable on long term debt.
 Consolidated Financial Statements

 Note 11. Commitments, Contingencies and Guarantees, page F-27

 5. Explain to us why not including informa tion about the legal proceeding initiated
by Cyntegra in June 2006 was considered appropriate.  We found no disclosures
included in your most recent periodic re port filed on May 2, 2007 related to this
matter.  SFAS 5 and SAB 92 require certain disclosures including a) disclosure of
the estimated loss, or range of loss, that is reasonably possible, or b) disclosure
that such an estimate cannot be made.  If an estimate cannot be made, the facts and circumstances that prevent management  from making such an estimate should
be disclosed.  Please provide us disclosure s in disclosure-type format that comply
with SFAS 5 and SAB 92 requirements. In addition, provide disclosures as
required by Item 103 of Regulation S-K in  disclosure-type format and proposed
disclosures to be included in your MD&A  about the contingency if you conclude
these disclosures are required.
 Note 16. Segment Reporting

6. Long-lived assets by geographic areas shoul d not include intangible assets.  Refer
to question 22 in the FASB Implementation Guide to FAS 131.  Provide us revised disclosure.  You may provide your current disclosure in addition to that
required by the standard.
 Exhibits 31.1 and 31.2

 7. In future filings please ensure that the certifications’ language is exactly the same
as the language required by Item 601 of Regulation S-K.  For example, do not

Ms. Merilee Raines
IDEXX Laboratories, Inc. May 22, 2007 Page 4
 replace the word “report” w ith “annual report” or “quart erly report” in paragraphs
1, 2, 3, and 4.   Please provide us revised ce rtifications in disclosure-type format.
 Form 10-Q March 31, 2007

 Condensed Consolidated Financial Statements

 Notes to Condensed Consolidated Financial Statements, page 6

 Note 2. Business Acquisitions, page 6

 8. Please provide us the analysis that form ed the basis for your conclusion that pro
forma information and disclosures rega rding acquisitions were not required.
Please give us a description of the factors that contributed to a purchase price that
resulted in the recognition of goodwill to be  included in future filings (paragraph
51b of FAS 141).  Please tell us why appa rently no amounts were allocated to any
customer relationships acquired and how that was consistent with SFAS 141 and
EITF 02-17.
 Item 2. Management’s Discussion and Analys es of Financial Condition and Results of
Operations, page 13

Liquidity and Capital Resources, page 20
 9. Your discussion of cash used by operations merely reiterates what is presented on
the statement of cash flows.  Cash wa s provided by operations for the years 2006,
2005 and 2004.  Please provide us expande d disclosure which discusses the
underlying reasons that cash was us ed in the first quarters.

*    *    *    *

 Please respond to these comments within 10 business days or tell us when you
will provide us with a response.   Please furnish a letter that keys your response to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish your letter on E DGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing include all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Ms. Merilee Raines
IDEXX Laboratories, Inc. May 22, 2007 Page 5
  In connection with responding to our co mments, please provide, in your letter, 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 filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact Ibolya I gnat, Staff Accountant at  (202) 551-3656, or Lisa
Vanjoske, Assistant Chief Accountant, at ( 202) 551-3614 if you have questions regarding
the comments.  In this regard, do not he sitate to contact me, at (202) 551-3679.

Sincerely,   Jim B. Rosenberg Senior Assistant Chief Accountant