Inter Parfums, Inc.

551 Fifth Avenue

New York, NY 10176

November 23, 2010

United States

Securities and Exchange Commission

100 F Street, NE., Stop 4631

Washington, D.C. 20549

Att.: Mr. Rufus Decker, Accounting Branch Chief

Re: Form 10-K for the Year Ended December 31, 2009

Form 10-Q for the Periods Ended March 31, 2010 and June 30, 2010

File No. 0-16469

Ladies and Gentlemen:

This letter is written in response to the letter dated November 9, 2010 of Mr. Rufus Decker, Accounting Branch Chief, addressed to Mr. Russell Greenberg, the Chief Financial Officer of Inter Parfums, Inc. (the “Staff Letter”). We have reproduced the comments from the Staff Letter, and our responses follow each of such comments.

Comment from Staff Letter:

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2009

General

1. Where a comment below requests additional disclosure or other revisions to be made, please show us in your supplemental response what the revisions will look like. These revisions should be included in your future filings.

Company response:

1.           Below are our responses to the comments set forth in the Staff Letter, which provide the requested information, and we acknowledge that all revisions will be included in future filings.

Item 6 — Management's Discussion and Analysis of Financial Condition and Results of Operations, page 32

Contractual Obligations, page 47

2. Please revise your table of contractual obligations to clarify whether the interest due amounts are included or excluded from the long-term debt line item and address the payments you are obligated to make under your interest rate swap agreement. If you have already included the interest rate swap amounts in the interest due amounts in footnote (2), please revise your disclosure to clarify this. Please also disclose any assumptions used to derive estimated interest payments and estimated payments under interest rate swaps.

Company response:

2. The interest due amounts which include the interest rate swap amounts will be included in long-term debt on the contractual obligations table. The interest rate swap exchanged a variable rate of interest for a fixed rate of interest. As all long-term debt now bears interest at a fixed rate, there are no assumptions used to derive interest payments. The disclosure in the footnote to the table relating to long term debt to be included in future filings will be in substantially the following form:

(2) Includes long-term debt and related interest costs including interest rate swap amounts. Interest due as the result of interest rate swaps is all at a fixed rate and is payable $0.70 million, $0.40 million and $0.07 million in 2010, 2011 and 2012, respectively.

Item 14 — Exhibits, Financial Statement Schedules, page 82

Consolidated Financial Statements and Schedule, page F-1

Consolidated Statements of Changes in Shareholders' Equity and Comprehensive Income, page F-5

3. Please revise your presentation to separately disclose comprehensive income attributable to Inter Parfums, Inc. and comprehensive income attributable to noncontrolling interest. Refer to ASC 220-10-45-5 and ASC 810-10-501A(a).

Company response:

3. In future filings we will add Consolidated Statements of Comprehensive Income which will separately disclose comprehensive income attributable to Inter Parfums, Inc. and comprehensive income attributable to the noncontrolling interest. A pro forma such statement is attached hereto as Exhibit A.

4. It is not clear why there is no foreign currency translation adjustment attributable to noncontrolling interest. Please tell us how you concluded your presentation was appropriate based on the guidance set forth in FAS ASC 220.

Company response:

4. When noncontrolling interest was moved into equity pursuant to ASC 810-10-45, our original thought was that assets and liabilities should be translated at the exchange rate at the balance sheet date pursuant to ASC 830-30-45-3a with 100% of the exchange gain or loss included in comprehensive income of the parent. Upon further review, we have determined that accumulated translation adjustments attributable to the noncontrolling interests should be allocated to and reported as part of the noncontrolling interest. The reclassification which we deem to be immaterial only affects the 2009 period and will be reflected in future filings. A pro forma of the reclassified Consolidated Statements of Changes in Equity is attached hereto as Exhibit B.

5.  Please revise your presentation to clarify that the number of common shares column represents the number of common shares outstanding.

Company response:

5. In future filings we will add the word "outstanding" to the common stock heading of the Consolidated Statements of Changes in Equity. A pro forma reflecting such change is attached hereto as Exhibit B.

Consolidated Statements of Cash Flow, page F-6

6.  Please tell us how you determined that proceeds from the sale of stock of a subsidiary and the payment for acquisition of noncontrolling interests should be classified in the cash used in investing activities section instead of the cash provided by (used in) financing activities in circumstances when Inter Parfums maintains control of the subsidiary, since these tranactions are accounted for as equity transactions. Refer to FASB ASC 230.

Company response:

6.   In 2008 and 2007, we acquired a 3.6% and 1.2% interest, respectively, in Inter Parfums, S.A., our majority owned French subsidiary, from its minority shareholders for cash of approximately $18.5 million in 2008 and $6.3 million in 2007. The acquisition was accounted for under the purchase method.

In addition, in June 2007, the minority shareholders of Nickel S.A., a consolidated subsidiary of the Company, exercised their rights to sell their remaining 32.4% interest in Nickel S.A. to the Company for approximately $4.7 million in cash. The acquisition was also accounted for under the purchase method.

These tranactions occurred prior to the effective date of ASC topic 805-10-05 (formerly SFAS 141 (revised 2007), “Business Combinations”). Since purchase accounting was used to record these transactions, it seemed reasonable to treat the acquisition as investing activities. In addition, with respect to the purchases of additional interest in Inter Parfums, S.A., our majority owned French subsidiary, the purpose of these transactions were to fight the dilution from the sale of shares resulting from the exercise of stock options. Therefore, treating the sale of stock of subsidiary from stock option exercises as an investing activity also seemed appropriate.

However, currently ASC 805-10-05 is effective and additional noncontrolling interests acquired or sold are accounted for as equity transactions. Pursuant to ASC 230-10-45, it appears that these transactions are cash inflows from and outflows for financing transactions. Future filing will reflect these transactions as financing transactions and prior periods will be reclassified to conform to current period presentation. A pro forma of the Consolidated Statements of Cash Flows is attached hereto as Exhibit C.

Note 9 — Commitments, page F-21

Leases, page F-21

7. Please disclose how you account for (a) step rent provisions and escalation clauses and (b) capital improvement funding and other lease concessions, which may be present in your leases. Lease payments that depend on an existing index or rate, such as the consumer price index or the prime interest rate, should also be included in your minimum lease payments. If, as we assume they are taken into account in computing your minimum lease payments and the minimum lease paymets are recognized on a straight-line basis over the minumum lease term, the note should so state. If our assumption is incorrect, please tell us how your accounting complies with FASB ASC 840.

Company response:

7.  Rent expense is calculated on a straight-line basis taking into account step rent provisions and rent concessions, but excludes the amounts due for escalation clauses tied to an index or rate as they are not material. In addition, we do not have any material capital improvement fundings. The disclosure in note 9 (Commitments) to the Consolidated Financial Statements relating to Leases to be included in future filings will be modified in substantially the following form:

Leases

The Company leases its office and warehouse facilities under operating leases which are subject to various step rent provisions, rent concessions and escalation clauses expiring at various dates through 2015. Escalation clauses are not material and have been excluded from minimum future annual rental payments. Rental expense, which is calculated on a straight-line basis, amounted to $9.9 million, $9.9 million and $9.1 million in 2009, 2008 and 2007, respectively. Minimum future annual rental payments are as follows: [table omitted].

FORM 10-Q FOR THE PERIOD ENDED JUNE 30, 2010

General

8. Please address the above comments in your interim filings as well.

Company response:

8.  To the extent any of our answers to the comments above affect our interim filings, we agree to make the appropriate modification in our subsequent interim filings.

Item 1 — Financial Statements, page 1

General

9. We note your presentation of comprehensive income on page 13. FASB ASC 220-10-45-8 requires a statement of comprehensive income that is displayed with the same prominence as your other financial statements. As such, please present your statement of comprehensive income within (1) your statements of income, (2) your statements of changes in equity, or (3) as a separate financial statement. Please revise accordingly.

Company response:

9.  We agree to present Consolidated Statements of Comprehensive Income as a separate financial statement in future interim filings for all periods presented. A pro forma of such statement is attached hereto as Exhibit D.

Consolidated Balance Sheets, page 2

10. The column heading on your June 30, 2010 balance sheet indicates that these amounts are unaudited, which implies that your December 31, 2009 balance sheet includes amounts that are audited. Since none of the amounts are converted by an audit report when they are presented in your interim financial statements for the period ended June 30, 2010, you should not imply that the December 31, 2009 balance sheet amounts are audited. Please revise.

Company response:

10.  In future interim filings we agree to remove the word "unaudited" from the consolidated balance sheets column heading for the current period, but will include the word "unaudited" in the heading of the consolidated balance sheets so each of the consolidated balance sheets presented will be unaudited.

* * * *

As requested, we acknowledge the following:

· the company is responsible for the adequacy and accuracy of the disclosure in their 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.

I trust that this adequately addresses your questions. However, if further information is required, please feel free to contact the undersigned.

Very truly yours,

Russell Greenberg,

Executive Vice President

and Chief Financial Officer

Exhibit A

INTER PARFUMS, INC. AND SUBSIDIARIES

Consolidated Statements of Comprehensive Income

Years ended December 31, 2009, 2008, and 2007

(In thousands except share and per share data)

	2009			2008			2007
Net income	$	30,158		$	30,122		$	30,601
Other comprehensive income (loss):
Net derivative instrument gain (loss), net of tax		173			5,829			(47	)
Reclassification from OCI into earnings, net		(5,922	)		-			-
Translation adjustments, net of tax		8,767			(12,643	)		21,270
		3,018			(6,814	)		21,223
Comprehensive income		33,176			23,308			51,824
Comprehensive income attributable to noncontrolling interests:
Net income		7,791			6,357			6,784
Net derivative instrument gain (loss), net of tax		(1,499	)		1,514			(16	)
Reclassification from OCI into earnings, net		32			-			-
Translation adjustments, net of tax		1,978			(2,888	)		5,454
		8,302			4,983			12,222
Comprehensive income attributable to Inter Parfums Inc.:	$	24,874		$	18,325		$	39,602

Exhibit B

INTER PARFUMS, INC. AND SUBSIDIARIES

Consolidated Statements of Changes in Shareholders’ Equity

Years ended December 31, 2009, 2008, and 2007

(In thousands except share data)

													Accumulated
	Common stock						Additional						other
	outstanding						paid-in			Retained			comprehensive			Treasury stock						Noncontrolling
	Shares			Amount			capital			earnings			income			Shares			Amount			interest			Total
Balance – January 1, 2007		30,652,188		$	31		$	38,085		$	127,834		$	15,170			9,371,830		$	(25,848	)	$	44,075		$	199,347
Comprehensive income:
Net income		—			—			—			23,817			—			—			—			6,784			30,601
Foreign currency translation adjustments		—			—			—			—			15,816			—			—			5,454			21,270
Net derivative instrument loss, net of tax		—			—			—			—			(31	)		—			—			(16	)		(47	)
Dividends		—			—			—			(4,093	)		—			—			—			(1,594	)		(5,687	)
Shares issued upon exercise of stock options including income tax benefit of $915		228,150			—			1,720			—			—			(150,000	)		414			—			2,134
Stock compensation		—			—			218			437			—			—			—			168			823
Purchase of subsidiary shares from  noncontrolling interest		—			—			—			—			—			—			—			(3,206	)		(3,206	)
Sale of subsidiary shares to noncontrolling interest		—			—			—			—			—			—			—			2,260			2,260
Shares received as proceeds of option exercises		(82,126	)		—			—			—			—			82,126			(910	)		—			(910	)
Balance – December 31, 2007		30,798,212			31			40,023			147,995			30,955			9,303,956			(26,344	)		53,925			246,585
Comprehensive income:
Net income		—			—			—			23,765			—			—			—			6,357			30,122
Foreign currency translation adjustments		—			—			—			—			(9,755	)		—			—			(2,888	)		(12,643	)
Net derivative instrument gain, net of tax		—			—			—			—			4,315			—			—			1,514			5,829
Dividends		—			—			—			(4,039	)		—			—			—			(1,735	)		(5,774	)
Shares issued upon exercise of stock options including income tax benefit of $988		33,150			—			1,260			—			—			—			—			—			1,260
Stock compensation		—			—			452			304			—			—			—			134			890
Purchase of subsidiary shares from  noncontrolling interest		—			—			—			—			—			—			—			(8,462	)		(8,462	)
Sale of subsidiary shares to noncontrolling interest		—			—			215			—			—			—			—			2,463			2,678
Purchased treasury shares		(662,423	)		(1	)		—			—			—			662,423			(4,975	)		—			(4,976	)
Balance – December 31, 2008		30,168,939			30			41,950			168,025			25,515			9,966,379			(31,319	)		51,308			255,509
Comprehensive income:
Net income		—			—			—			22,367			—			—			—			7,791			30,158
Foreign currency translation adjustments		—			—			—			—			6,789			—			—			1,978			8,767
Reclassification from OCI into earnings, net														(4,423	)								(1,499	)		(5,922	)
Net derivative instrument gain, net of tax		—			—			—			—			141			—			—			32			173
Dividends		—			—			—			(3,974	)		—			—			—			(1,716	)		(5,690	)
Shares issued upon exercise of stock options including income tax benefit of $692		243,600			—			2,711			—			—			(150,000	)		476			—			3,187
Stock compensation		—			—			510			193			—			—			—			102			805
Sale of subsidiary shares to noncontrolling interest		—			—			(45	)		—			—			—			—			2,671			2,626
Purchased treasury shares		(108,100	)		—			—			—			—			108,100			(631	)		—			(631	)
Shares received as proceeds of option exercises		(132,487	)		—			—			—			—			132,487			(1,569	)		—			(1,569	)
Balance – December 31, 2009		30,171,952		$	30		$	45,126		$	186,611		$	28,022			10,056,966		$	(33,043	)	$	60,667		$	287,413

Exhibit C

INTER PARFUMS, INC. AND SUBSIDIARIES

Consolidated Statements of Cash Flows

Years ended December 31, 2009, 2008, and 2007

(In thousands)

	2009			2008			2007
Cash flows from operating activities:
Net income	$	30,158		$	30,122		$	30,601
Adjustments to reconcile net income to net cash provided by (used-in) operating activities:
Depreciation and amortization		10,963			9,925			8,031
Impairment of goodwill and trademark		2,213			936			868
Provision for doubtful accounts		1,394			148			588
Noncash stock compensation		947			1,119			1,096
Deferred tax (benefit) provision		(3,079	)		4,118			(657	)
Change in fair value of derivatives		(861	)		1,759			—
Gain on subsidiary’s issuance of stock		—			—			(665	)
Changes in:
Accounts receivable		20,912			(8,768	)		2,984
Inventories		40,628			(23,285	)		(28,677	)
Other assets		(4,841	)		4,010			(1,602	)
Accounts payable and accrued expenses		(18,900	)		(18,051	)		25,014
Income taxes payable, net		5,106			(8,461	)		936
Net cash provided by (used-in) operating activities		84,640			(6,428	)		38,517
Cash flows from investing activities:
Purchases of short-term investments		—			(5,144	)		(300	)
Proceeds from sale of short-term investments		—			5,144			13,100
Purchase of equipment and leasehold improvements		(5,526	)		(3,803	)		(2,380	)
Payment for intangible assets acquired		(775	)		(1,095	)		(58,723	)
Net cash provided by (used in) investing activities		(6,301	)		(4,898	)		(48,303	)
Cash flows from financing activities:
Proceeds from (repayment of) loans payable – banks		(9,005	)		7,089			762
Proceeds from issuance of long-term debt		—			—			54,948
Repayment of long-term debt		(12,408	)		(16,292	)		(10,440	)
Proceeds from sale of stock of subsidiary		2,658			2,695			2,879
Payment for acquisition of minority interests		—			(18,493	)		(10,984	)
Purchase of treasury stock		(660	)		(4,975	)		(107	)
Proceeds from exercise of options including tax benefits		1,648			1,260			1,331
Dividends paid		(3,974	)		(4,069	)		(3,879	)
Dividends paid to minority interest		(1,716	)		(1,735	)		(1,594	)
Net cash provided by (used in) financing activities		(23,457	)		(34,520	)		32,916
Effect of exchange rate changes on cash		3,181			(1,784	)		8,657
Net increase (decrease) in cash and cash equivalents		58,063			(47,630	)		31,787
Cash and cash equivalents – beginning of year		42,404			90,034			58,247
Cash and cash equivalents – end of year	$	100,467		$	42,404		$	90,034
Supplemental disclosures of cash flow information:
Cash paid for:
Interest	$	2,633		$	3,894		$	3,872
Income taxes		13,085			13,311			15,211

Exhibit D

INTERPARFUMS, INC. AND SUBSIDIARIES

CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME

(In thousands)

(Unaudited)

	Three months ended September 30,					Nine months ended September 30,
	2010		2009			2010			2009
Comprehensive income:
Net income	$	11,409	$	9,611		$	27,342		$	22,620
Other comprehensive income, net of tax:
Foreign currency translation adjustment		27,341		9,049			(12,423	)		13,251
Change in fair value of derivatives		968		(1,148	)		1,014			(1,919	)
Net gains reclassified into earnings from equity		—		(751	)		—			(2,329	)
Comprehensive income:		39,718		16,761			15,933			31,623
Less comprehensive income attributable to the noncontrolling interest		9,570		3,975			4,222			7,669
Comprehensive income attributable to Inter Parfums, Inc.	$	30,148	$	12,786		$	11,711		$	23,954