Larry Spirgel

Division of Corporation Finance

U.S. Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549-0609

Reference: Ambassadors Group, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2005

Filed March 9, 2006

File No 000-33347

Dear Mr. Spirgel:

Please find below our response to your letter, dated November 2, 2006, regarding our Annual Report on Form 10-K, filed with the United States Securities and Exchange Commission (the “Commission”) on March 9, 2006 (“Annual Report”). As requested, we have keyed our response to your comments and have attempted to provide you with a high level of detail. Of course, should you have any further questions, please contact me at any time at the telephone number indicated at the end of this letter.

We acknowledge that:

• Ambassadors Group is responsible for the adequacy and accuracy of the disclosures in the filing;

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

• Ambassadors Group 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 Question #1

We note your presentation of net revenues, gross revenue, less cost of sales, and net revenues from all programs. The presentation is not in accordance with Rule 5-03 of Regulation S-X. Please advise accordingly.

We have changed our presentation of net revenues, gross revenue, less cost of sales, and net revenues from all programs to comply with Rule 5-03 of Regulation S-X, as disclosed in our most recent 10-Q for the three and nine months ended September 30, 2006, filed on November 9, 2006. A copy of the Consolidated Statement of Operations from our November 9, 2006 Form 10-Q is attached. We will use this presentation in our prospective filings.

SEC Question #2

Please tell us how you determined that selling and tour promotion expenses and operating expenses related to your programs should not be classified as costs of sales.

The selling and tour promotion expenses primarily relate to advertising and direct marketing costs such as postage, printing, and related personnel costs. These costs are for the general marketing of future programs and are not directly related to the programs traveled in the current period. As such, we believe they are more appropriately classified as operating expenses in our Consolidated Statement of Operations.

In our most recent 10-Q for the three and nine months ended September 30, 2006, we have changed the description of these costs to “selling and marketing” as opposed to “selling and tour promotion” to provide a better description of the costs incurred. You will also see this change in the copy of the Consolidated Statement of Operations attached.

As I indicated above, we have attempted in this letter and its attachment to address all of the questions presented by your letter of November 2, 2006. In addition, both items set forth above have been appropriately addressed in our most recent Form 10-Q, filed on November 9, 2006. We believe that by addressing your comments in this letter and in our most recent Form 10-Q, we have eliminated the need to file an amendment to our Form 10-K for the fiscal year end December 31, 2005. We look forward to your confirmation that these items have been appropriately addressed and that the matter is concluded. Should you have any further questions, please contact me at telephone number 1-509-568-7617.

	Sincerely,
Date: November 20, 2006	/s/ Chadwick J. Byrd
	Chadwick J. Byrd
	Chief Financial Officer

AMBASSADORS GROUP, INC.

CONSOLIDATED STATEMENTS OF OPERATIONS (UNAUDITED)

For the three and nine months ended September 30, 2006 and 2005

(dollars in thousands, except per-share amounts)

	Nine months ended				Three months ended
	September 30,				September 30,
	2006		2005		2006		2005
Net revenue, non-directly delivered programs	$	65,222	$	61,676	$	33,174	$	29,805
Gross revenue, directly delivered programs		17,789		1,399		5,532		1,399
Total Revenue		83,011		63,075		38,706		31,204
Cost of sales, directly delivered programs		10,233		757		3,613		757
Gross Margin		72,778		62,318		35,093		30,447
Operating Expenses:
Selling and marketing		22,925		19,421		9,176		7,991
General and administrative		6,707		4,545		2,399		1,754
Total Operating Expenses		29,632		23,966		11,575		9,745
Operating income		43,146		38,352		23,518		20,702
Other income:
Interest income		3,626		2,010		1,263		765
Income before income taxes		46,772		40,362		24,781		21,467
Income tax provision		14,654		13,138		7,682		6,855
Net income	$	32,118	$	27,224	$	17,099	$	14,612
Net income per share — basic	$	1.56	$	1.34	$	0.83	$	0.72
Weighted-average common shares outstanding — basic		20,559		20,258		20,609		20,336
Net income per share — diluted	$	1.50	$	1.28	$	0.80	$	0.68
Weighted-average common shares outstanding — diluted		21,390		21,303		21,418		21,379

The accompanying notes are an integral part of the consolidated financial statements.

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