October 25, 2005

Mr. Richard L. Bergmark
Chief Financial Officer
Core Laboratories N.V.
Herengracht 424
1017 BZ Amersterdam
The Netherlands

	Re:	Core Laboratories N.V.
		Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 13, 2005

Dear Mr. Bergmark:

      We have reviewed your filings and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Where indicated, we think you should
revise your document in response to our comments.  If you
disagree, we
will consider your explanation as to why our comments are
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with information so we may better understand your disclosure.
After reviewing this information, we may raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We
look forward to working with you in these respects.  We welcome
any
questions you may have about our comments or any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

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

Financial Statements

Note 13 - Stock-based Compensation

1. We have reviewed your response to our comment in our letter
dated
September 8, 2005, and ask that you provide the following
additional
information.

(a) Please expand the charts that you provided on Attachments 1
and 2
to include each of the quarters of 2003.

(b) Please explain why you do not believe that it was appropriate
to
record expense in 2003 or 2004 for Tranche 2 and Tranche 3 of your
plan.

General

2. Please file your response dated October 5, 2005, as well as
your
future response(s), as Correspondence in Edgar.

Closing Comments

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

	You may contact Sandy Eisen at (202) 551-3864 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3684 with any other
questions.

								Sincerely,



								April Sifford
								Branch Chief

cc:  Sandy Eisen
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Mr. Richard L. Bergmark
Core Laboratories N.V.
October 25, 2005
page 1




UNITED STATES
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