Mail Stop 0308

      March 31, 2005

VIA U.S. MAIL AND FACSIMILE

Mr. James E. Skinner
Senior Vice President and Chief Financial Officer
The Neiman Marcus Group, Inc.
One Marcus Square
1618 Main Street
Dallas, Texas 75201

	RE:	Form 10-K for the Fiscal Year Ended July 31, 2004
		Form 10-Q for the Quarter Ended January 29, 2005
      File No. 1-9659

Dear Mr. Skinner:

		We have reviewed your filings and have the following
comments.  We have limited our review to your financial statements
and related disclosures and will make no further review of your
documents.  If you disagree with a comment, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

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


Form 10-K for the Year Ended July 31, 2004

General

1. Unless otherwise indicated, where a comment below requests
additional disclosures or other revisions to be made, please
include
the additional disclosures and revisions in your future filings.

Item 1.  Business

2. Please disclose for each of the last three years the percentage
or
amounts of revenues contributed by classes of your products that
accounted for 10% or more of revenues in any of the last three
years
as required by Item 101(c)(i) of Regulation S-K.

Item 5.  Market for the Registrant`s Common Equity and Related
Shareholder Matters

3. Please include a description of the nature of stock repurchase
transactions that were not made under publicly announced
repurchase
plans or programs as required by Item 703 of Regulation S-K.

Item 6.  Selected Financial Data

4. Please disclose cash dividends declared per common share as
required by Instruction 2 to Item 301 of Regulation S-K.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations
Operating Results, page 12
General

5. Please include a tabular presentation of net sales revenues by
product category for the periods presented and provide a narrative
discussion of the extent to which material changes are
attributable
to pricing, mix or volume of goods sold.  Please refer to SEC
Release
No. 33-8350 and Item 303(a)(3)(iii) of Regulation S-K.

6. In circumstances where you describe more than one business
reason
for a significant change between periods in key financial data or
indicators, please quantify, to the extent possible, the
incremental
impact of each individual business reason on the overall change.
For
example, in your comparison of operating results, you should
quantify, in terms of dollars, the:
* changes in comparable store revenues;
* changes in sales attributable to stores opened and closed and
excluded from comparable store revenues;
* changes in sales of brand development companies;
* increase in cost of sales from changes in product mix;
* changes in occupancy and buying costs, including payroll
expenses,
rent and related occupancy expenses;
* increases and decreases in margins from changes in markdowns;
* impact of changes in vendor allowances;
* increase in depreciation expense;
* reduction in pre-opening expenses; and
* changes in individual expenses included in selling, general and
administrative expenses, including incentive compensation and
income
from your credit card portfolio.
In those circumstances where you describe and quantify a change
between periods, please also provide an analysis of the business
reasons underlying the change.  For example, in your analysis you
should explain why:
* sales of brand development companies increased; and
* you recognized an impairment charge related to the Chef`s
catalog
tradename intangible asset.

7. Please provide an analysis of the operating earnings of your
other
operating segment for the periods presented.  In doing so, please
quantify and discuss the changes in the operating results of brand
development companies and corporate expenses.

Financing Structure, page 20

8. Please identify any significant covenants of your unsecured
senior
notes and debentures.  Also, disclose the repercussions of not
meeting significant covenants of your credit agreement and
unsecured
senior notes and debentures and the existence of any cross-default
provisions.  These disclosures should also be included in the
notes
to your financial statements.

Contractual Obligations and Commitments, page 21

9. Please include other long-term liabilities reflected on your
balance sheet.  If an obligation does not have a due date and is
excluded from the table, disclose the amount of the excluded
obligation and why it is not possible to estimate a payment date.
Please see Item 303(a)(5) of Regulation S-K.

Critical Accounting Policies, page 24

10. Please disclose the amounts of estimates that materially
affected
your reported earnings and the amounts of the related valuation
allowances for each period presented.  For example, disclose your
provisions for product returns and doubtful accounts, your
estimates
related to impairment of long-lived assets, and the related
valuation
allowances where applicable.  Please also provide an analysis of
material changes in each of your critical accounting estimates,
including changes in depreciable lives, on revenues, operating
expenses and gross profit for the periods presented.  In addition,
discuss to the extent material how accurate your estimates and
assumptions have been in the past and whether the estimates are
reasonably likely to change in the future.  Further, provide a
sensitivity analysis of the potential impact of using different
assumptions.  Please refer to SEC Release No. 33-8350.

Item 10.  Directors and Executive Officers of the Registrant

11. Please tell us if you intend to satisfy the disclosure
requirements under Item 5.05 of Form 8-K regarding an amendment
to,
or a waiver from, a provision of your code of ethics that applies
to
your principal executive officer, principal financial officer,
principal accounting officer or controller, or persons performing
similar functions and that relates to any element of your code of
ethics by posting such information on your Internet website.  If
so,
please disclose your intention.

Item 11.  Executive Compensation

12. Please disclose or incorporate by reference to the appropriate
captions of your proxy statement the information required by Items
402(h) and 402(j) of Regulation S-K.

Item 12.  Security Ownership of Certain Beneficial Owners and
Managements and Related Shareholders Matters

13. Please disclose or incorporate by reference to the appropriate
captions of your proxy statement the information required by Item
201(d) of Regulation S-K.

Schedule II, page 36

14. Please disclose the information required by Rule 12-09 of
Regulation S-X with respect to your allowance for estimated sales
returns as required by Rule 5-04(a)(2) of Regulation S-X.  Please
also describe amounts charged to deductions in footnotes to the
table.

Consolidated Financial Statements
Consolidated Balance Sheets, page F-3

15. Tell us if there are any individual items included in the
"other
long-term liabilities" caption that exceed 5% of total
liabilities.
If so, these items should be disclosed in the notes to the
financial
statements or on the face of your balance sheets.  See Rule 5-
02(20)
of Regulation S-X.


Consolidated Statements of Cash Flows, page F-5

16. Please explain to us how you account for and report cash flows
between you and the securitization trust.  Tell us what proceeds
from
maturities and purchases of held-to-maturity securities related to
your undivided interests in NMG Credit Card Master Trust
represent.
Provide to us a summary of the cash flows between you and the
Trust
for the periods presented.  Please include proceeds from new
securitizations, proceeds from collections reinvested in revolving
period securitizations, purchases of delinquent or foreclosed
loans,
servicing fees and proceeds received on retained interests.
Please
tell us how your disclosures comply with the requirements of
paragraph 17.f.(4) of SFAS 140.  We may have further comment.

17. Please disclose information about all investing and financing
activities for each period presented that affect recognized assets
or
liabilities but that do not result in cash receipts or cash
payments
as required by paragraph 32 of SFAS 95.  Please provide us with
revised disclosures that you would use in future filings.

Consolidated Statements of Shareholders` Equity, page F-6

18. Please provide to us a reconciliation of changes in
stockholders
equity from issuance of shares under stock option plans and other
equity transactions to the amounts of proceeds from exercises of
stock options and restricted stock awards in your statements of
cash
flows for the periods presented.

19. Please disclose accumulated balances for each component of
accumulated other comprehensive income as required by paragraph 26
of
SFAS 130.  Please also disclose reclassification adjustments for
each
classification of other comprehensive income, except minimum
pension
liability, on the face or in the notes to your financial
statements
as required by paragraphs 19 and 20 of SFAS 130.

Notes to Consolidated Financial Statements
Note 1.  Summary of Significant Accounting Policies
Estimates and Critical Accounting Policies
Cash and Cash Equivalents, page F-7

20. We assume that outstanding drafts included in accounts payable
represent book overdrafts in your zero balance accounts.  Please
tell
us if our assumption is correct.  If so, please disclose where you
present the net change in book cash overdrafts in your statements
of
cash flows.  If your outstanding drafts represent bank overdrafts,
please tell us why you do not classify the net change in bank
overdrafts in cash flows from financing activities pursuant to the
guidance in AICPA Technical Practice Aid Section 1300.15.


Long-Lived Assets, page F-9

21. Please tell us the effect of changes in the useful lives of
property, plant and equipment during the years presented and where
you disclosed the changes in your financial statements.  If you
have
not disclosed the changes in estimates in your financial
statements,
please tell us why.  If the effects of the changes are material,
please disclose the effects on net income and related per share
amounts in the notes to your financial statements as required by
paragraph 33 of APB 20.

Revenues, page F-10

22. Please tell us the amount of net commissions earned from
leased
departments for the periods presented.  If revenues from leased
departments exceed 10% of revenues, please disclose your revenue
recognition policy and the amount of net commissions earned for
each
period presented on the face of your statement of earnings as
required by Rule 5-03(a)(1) of Regulation S-X.

Selling, General and Administrative Expenses, page F-10

23. Please disclose the revenues and expenses of your proprietary
credit card operations as required by SAB Topic 8:B.  In doing so,
please disclose interest and fees and income from retained
interests,
including servicing fees, and your provisions for doubtful
accounts
for each period presented.

Stock-Based Compensation, page F-11

24. Pursuant to paragraph 45.c. of SFAS 123, as amended by SFAS
148,
if awards of stock-based employee compensation are outstanding and
accounted for under the intrinsic value method of APB 25 for any
period for which an income statement is presented, the required
tabular presentation should include stock-based employee
compensation
cost, net of related tax effects, included in the determination of
net income and the stock-based employee compensation cost, net of
related tax effects, that would have been included in the
determination of net income if the fair value based method had
been
applied to all awards.  Tell us why you do not reflect
amortization
of unearned compensation charged to income in your pro forma
disclosure.  Otherwise, please revise your tabular presentation to
disclose stock-based employee compensation cost, net of related
tax
effects, included in the determination of net income and stock-
based
employee compensation cost, net of related tax effects, that would
have been included in the determination of net income if the fair
value based method had been applied to all awards.  Please
disclose
the weighted average grant-date fair value of restricted stock and
purchased restricted awards granted during each period presented
as
required by paragraph 47.c. of SFAS 128.

25. We note that you initiated a quarterly cash dividend during
2004.
Please tell us why you did not include the expected dividend yield
in
the assumptions used in the option pricing model to estimate the
fair
value of employee stock-based compensation awards granted
subsequent
to the initiation of the quarterly dividend.  Please refer to
paragraph 19 of SFAS 123.

Note 2.  Securitization of Credit Card Receivables, page F-13

26. Please explain to us in detail the provisions contained in the
securitization agreement that provide you with the rights to
repurchase the Class A certificates and regain effective control
over
the credit card receivables held by the Trust.  In doing so, tell
us:
* whether your rights to repurchase the Class A Certificates and
regain control over the assets were contingent upon future events
and
circumstances and that did not provide you with the unilateral
right
to regain control of the assets at the inception of the
securitization agreement;
* why the rights did not initially preclude sale accounting under
paragraph 9(c) of SFAS 140;
* the change or other circumstances that now provide you with the
unilateral ability to regain control of the assets previously
sold;
* the circumstances and/or events that trigger the exercisability
of
your rights to repurchase the Class A Certificates and regain
control
over the assets;
* why your rights to repurchase the Class A Certificates and
regain
control over the assets are no longer contingent upon future
events
and circumstances; and
* why it is necessary to estimate when the rights will become
exercisable.
Please also explain to us how your re-recognition accounting
treatment complies with the requirements of paragraph 55 of SFAS
140
and each of the applicable consensuses reached in EITF 02-09.  If
your accounting treatment does not comply with the requirements of
paragraph 55 of SFAS 140 and the applicable consensuses reached in
EITF 02-09, tell us the justification in GAAP for your accounting
treatment and the use of a transition period.  In particular,
please
explain in detail:
* how you measured the credit card receivables repurchased and the
obligation to the holders of the Class A certificates;
* whether or not you recognized a gain or loss on the transaction
and
why, and the amount of the gain or loss;
* your recognition of a loan loss allowance related to the
repurchased credit card receivables; and
* your accounting treatment of the retained interests and their
combination with the re-recognized assets.
In addition, we note that you reflected proceeds from borrowings
under the credit card facility in your statements of cash flows.
Please tell us why the re-recognition of credit card receivables
and
the related assumption of the obligation to holders of the Class A
certificates should be reported as cash outflows and cash inflows
in
your statements of cash flows.

27. We note that you classify retained interests in a manner
similar
to debt securities held to maturity. Please tell us your
justification in GAAP for doing so.  Please refer to paragraph 14
of
SFAS 140.  Please disclose the fair value of your retained
interests,
unrecognized holding gains or losses and the net carrying amount
of
the retained interests in the notes to your financial statements
for
each period presented.  Refer to paragraph 19 of SFAS 115, as
amended.

Note 10.  Impairment and Other Charges, page F-27

28. We note that you were exploring strategic alternatives,
including
sale, merger, joint venture or other business combination related
to
your Chef`s Catalog brand and that you recognized an impairment
loss
related to the Chef`s Catalog tradename of $3.9 million.  We also
note that you subsequently sold your Chef`s Catalog business and
reported a pre-tax loss of $15 million during the quarter ended
October 30, 2004.  As part of your impairment testing as of July
31,
2004, we would have expected you to reflect the alternative
courses
of action you were considering in your probability weighted-
average
estimate of future cash flows related to your Chef`s Catalog
brand.
See paragraph 17 of SFAS No. 144.  Please explain to us in detail
your testing of the recoverability of the long-lived assets of
your
Chef`s Catalog business at July 31, 2004 and the significant facts
and circumstances that resulted in the change in estimate.  Please
disclose the facts and circumstances leading to the impairment of
your Chef`s Catalog business.  Please also disclose the facts and
circumstances leading to the impairment Kate Spade LLC and Neiman
stores.

Note 14.  Segment Information, page F-29

29. Your corporate expenses should not be combined with the
results
of your brand development companies under the aggregation criteria
of
paragraph 17 of SFAS 131.  Please revise to separately report
information about your brand development companies and corporate
expenses.  Refer to paragraphs 17 and 19 of SFAS 131.  Please
disclose revenues from each group of similar products and services
as
required by paragraph 37 of SFAS 131.

Form 10-Q for the Quarter Ended January 29, 2005

Condensed Consolidated Statements of Earnings, page 2

30. Please tell us why your Chef`s Catalog business does not meet
the
criteria of paragraphs 41 and 42 of SFAS 144 for reporting as
discontinued operations in accordance with paragraph 43 of SFAS
144.


Notes to Condensed Consolidated Financial Statements
Note 1.  Basis of Presentation, page 4

31. We note you characterized your misclassification of
construction
allowances as a reclassification, as opposed to a correction of an
error.  We refer you to Don Nicholaisen`s letter dated February 7,
2005, which characterizes corrections in lease accounting for
Landlord/Tenant Incentives as the correction of an accounting
error
and states that "The SEC staff believes that the positions noted
above are based upon existing accounting literature and
registrants
who determine their prior accounting to be in error should state
the
restatement results from the correction of errors."  Please amend
your filing, or tell us why you do not believe an amendment is
necessary to:
* clarify that the reclassification is a correction of an error in
accordance with APB 20;
* include a tabular presentation of the as reported and as
restated
amounts so that readers will understand the impact that the
reclassification had on operating and investing cash flows; and
* disclose the effect of the correction on depreciation expense
and
rent expense for the periods presented.
In addition, it appears that you present changes in deferred real
estate credits as an adjustment to reconcile net earnings to net
cash
provided by operating activities in your cash flows from
operations
in your statements of cash flows.  Please tell us why you do not
reflect such changes as changes in operating assets and
liabilities.
Also, please confirm to us that the lease term over which you
amortize your leasehold improvements and deferred real estate
credits
is consistent with the definition in paragraph 5.f of SFAS No. 13.

Note 7.  Employee Benefit Plans, page 9

32. Please tell how you implemented the provisions contained in
FSP106-2 during the period ended January 29, 2005.  In doing so,
tell
us if you;
* elected the deferral provided by FSP 106-1;
* concluded whether your prescription drug benefits are
actuarially
equivalent to Medicare Part D and qualify for the subsidy under
the
Medicare Prescription Drug, Improvement and Modernization Act of
2003;
* concluded that the enactment of the Act was a significant event
pursuant to paragraph 73 of SFAS 106; and
* amended your postretirement plan after the enactment of the Act.
If you amended your postretirement plan after the enactment of the
Act, tell us whether your accounting for the effects of the Act
differed from the guidance in FSP 106-2 and whether you followed
the
guidance in paragraph 32.  If you concluded that the enactment of
the
Act was a significant event pursuant to paragraph 73 of SFAS 106,
tell us whether you adopted FSP 106-2 prospectively or
retroactively.
Please disclose the information required by paragraphs 20 and 21
of
FSP 106-2 as applicable.

Item 6.  Exhibits

33. Please file, either by including or incorporating by
reference,
all of the exhibits required by Item 601(a) of Regulation S-K.
See
paragraph 2 in the Instructions to the Exhibit Table.

*	*	*	*	*	*

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the 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 respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a supplemental response letter that keys your responses to
our comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

      If you have any questions regarding these comments, please
direct them to Bill Thompson at (202) 942-1935 or Nili Shah at
(202)
942-2923, or in their absence, to the undersigned at (202) 942-
2823.

							Sincerely,



								Mike Moran
								Accounting Branch Chief
??

??

??

??


March 31, 2005
Page 1