September 21, 2007

VIA OVERNIGHT DELIVERY AND FACSIMILE
(202) 772-9202

Ms. Hanna T. Teshome, Special Counsel
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010

Mail Stop: 3561

Re: IDEX Corporation Response to Comment Letter dated August 21, 2007
    Definitive 14A Proxy Statement filed March 7, 2007 ("Proxy Statement")
    File No. 001-10235

Dear Ms. Teshome:

The following represents IDEX Corporation's (the "Company") response to the
comments of the staff of the Division of Corporation Finance in your letter,
dated August 21, 2007, to Mr. Lawrence D. Kingsley with respect to the Company's
Proxy Statement. For ease of reference each comment is repeated in italics below
and followed by the Company's response.

Transactions with Related Persons, page 8

1. Please provide the information required by Item 404(b). For example, describe
your policies and procedures for the review, approval, or ratification of any
transaction required to be reported under Item 404(a), including, to the extent
applicable, the material features described in Item 404(b)(1).

The Company has previously attached a copy of its two-page related party
transaction policy as an exhibit to the Proxy Statement. However, in future
filings the Company will instead expand the discussion in the Proxy Statement of
its review of related party transactions to include the information required by
Item 404(b) as follows:

"All related party transactions are approved by the Audit Committee. If the
transaction involves a related person who is a director or immediate family
member of a director, that director will not be included in the deliberations.
In approving the transaction, the Audit Committee must determine that the
transaction is fair and reasonable to the Company."



Executive Compensation, page 11

Compensation Discussion and Analysis, page 11

Total Compensation, page 11

2. You indicate that the variable component of compensation is based on
individual performance or on both individual and company performance. Please
revise your discussion with respect to each element of the variable component of
compensation to clarify how the amount for each element is determined and
clarify how the variable component of compensation is structured to reflect
individual performance with respect to the specified elements of performance
that is taken into account for determination compensation. Please refer to Item
402(b)(1)(v) and 402(b)(2)(vii) of Regulation S-K.

In future filings the Company will clarify how the variable component of
compensation is structured to reflect individual performance and, where
applicable, the specific elements of performance that are taken into account for
determination of compensation.

We respectfully submit that, on page 14 of the Proxy Statement, we already
disclose in detail how individual performance impacts the annual cash bonus
component of a named executive officer's compensation through the use of the
Personal Performance Multiplier. In addition, on page 15 of the Proxy Statement,
we describe the impact of individual performance on the level of stock option
and restricted stock awards. However, we will attempt to clarify further in
future filings that a named executive officer's individual performance
determines the level of the officer's bonus and the number of stock options and
restricted stock awards.

Please note that for 2006, individual performance was not based on any specific
elements, but rather the Compensation Committee's subjective opinion of the
officer's overall performance of his duties. For named executive officers other
than Mr. Kingsley, the Compensation Committee's review of the officer's overall
performance and the Personal Performance Multiplier was primarily based on Mr.
Kingsley's subjective review and opinion of each individual's performance, which
was provided to the Compensation Committee.

3. Please revise your disclosure to provide all the performance-related factors,
quantitative and qualitative, considered to determine the amount payable under
each component. To the extent you believe that disclosure of performance targets
is not required because it would result in competitive harm such that it could
be excluded under Instruction 4 to Item 402(b) of Regulation S-K, please provide
a supplementary analysis supporting your conclusion. You should provide detailed
explanation for your conclusion as to competitive harm and also revise your
disclosure to discuss how difficult it would be for the named executive officers
or how likely it will be for you to achieve the undisclosed target levels or
other factors. General statements regarding the level of difficulty, or ease
associated with achieving performance goals are not sufficient. In discussing
how difficult it will be for an executive or how likely it will be for you to
achieve the target levels or other factors, you should provide as much detail as
necessary without providing information that would result in competitive harm.
You should provide insight into the factors considered by the compensation
committee prior to awarding of performance-based compensation such as historical
analyses prior to the granting of these awards or


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correlations between historical bonus practice and the incentive parameters set
for the relevant fiscal period.

In future filings the Company will clarify the disclosure of its performance
related factors considered in determining the amount payable under each
component, including, insight into the factors considered by the Compensation
Committee prior to awarding of performance-based compensation.

The Company respectfully submits that its disclosure on page 14 of the Proxy
Statement fully describes all quantitative factors used to determine the
Business Performance Factor component of annual bonuses and, therefore, no
further disclosure regarding quantitative factors is necessary.

The Company also respectfully submits that on page 14 of the Proxy Statement we
described the qualitative factors used to determine the Business Performance
Factor component of annual bonuses under the MICP as being behavior oriented
toward business and process leadership. The Company believes that such
description sufficiently informs our shareholders of the type of qualitative
factors used in determining the annual bonuses. Because the actual twelve
qualitative factors are subjective and intangible, the Company specifically
decided not to list each one in the Proxy Statement. Rather, the Company
determined that inclusion would not provide any further meaningful disclosure to
our shareholders, and would interfere with the goal of providing a concise and
clear description of the bonus determination.

Please be advised that, for 2006, the twelve qualitative factors were: energy;
energize; edge; execution; business metrics development; cultural transformation
to value stream thinking; strategic sourcing methodologies; new product
development and innovation management; commercial excellence; people
development, differentiation, and upgrading of talent; integration
effectiveness; and customer relationships and responsiveness. Because each of
these qualitative factors is purely subjective and intangible, the Committee's
determination of each business unit's performance is completely discretionary.
We would not intend to list all twelve factors in the future, since they do not
provide any further meaningful disclosure than the general categorical
description already contained in the Proxy Statement.

4. With respect to each element of variable compensation, please revise your
disclosure to clarify the extent to which discretion can be exercised to adjust
an award. To the extent discretion has been exercised, discuss the particular
exercise of discretion so that the disclosure clearly explains how that specific
element of compensation was determined. For example, you indicate on page 15
that the compensation committee exercised its discretion to adjust the CEO's
annual cash bonus. It is unclear, however, what the committee took into account
in that exercise of discretion. Please refer to Item 402(b)(2)(vi) of Regulation
S-K.

In future filings the Company will clarify the extent to which discretion can be
exercised and to the extent discretion has been exercised to discuss that
particular exercise of discretion so that the disclosure more clearly explains
how that specific element of compensation was determined.

Please be advised that page 14 of the Proxy Statement already contains
disclosure regarding the Compensation Committee's discretion to adjust the
Business Performance Factor used in


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 determining annual bonus awards under the MICP, and that the Compensation
Committee did in fact use its discretion to adjust the factor in 2006 based the
Company's acquisition activities. As indicated by the existing disclosure, there
is no limitation on the Compensation Committee's discretion.

Please be advised, that as stated on page 14 of the Proxy Statement the
Compensation Committee exercised its discretion to adjust Mr. Kingsley's
performance award downward. In exercising this discretion, the Compensation
Committee applied the same quantitative targets discussed on pages 13 and 14 of
the Proxy Statement with respect to bonuses under the MICP to Mr. Kingsley to
determine what bonus he would have received under that plan, if he were a
participant in MICP with an individual target bonus of 100% of base salary. In
addition, the Compensation Committee's determination included a subjective
assessment of Mr. Kingsley's overall performance.

Role of the Compensation Committee and Data Used, page 12

5. You state that you engaged an independent outside consultant to assist in the
company's compensation programs. Please describe in greater detail the nature
and the scope of the consultant's assignment and the material elements of the
instructions and directions given to the consultants with respect to the
performance of their duties under the engagement. Please refer to Item
407(e)(3)(iii) of Regulation S-K.

In future filings the Company will expand its disclosure regarding the nature
and scope of the compensation consultant and the material elements of the
instructions and directions given to the consultant with respect to the
performance of its duties under its engagement.

Please be advised that for 2006, the Compensation Committee discussed its
compensation philosophy with Towers Perrin, as described in the Compensation
Discussion & Analysis, but otherwise did not impose any specific limitations or
constraints on, or otherwise direct, the manner in which Towers Perrin performed
its advisory services. During 2006, Towers Perrin's primary areas of assistance
were:

     -    Gathering market compensation data for several executive positions;

     -    Developing and presenting "tally sheets" to the Compensation
          Committee;

     -    Reviewing materials to be used in the Company's 2007 proxy statement.

In addition, Towers Perrin periodically provides the Compensation Committee and
management market data on a variety of compensation-related topics. The
Compensation Committee authorized Towers Perrin to interact with the Company's
management, as needed, on behalf of the Compensation Committee, such as to
obtain or confirm information.

6. You indicate that the compensation committee evaluates market data for
purposes of determination compensation with additional market reference
considerations for the CEO's compensation. Please revise your disclosure to
clarify your benchmarking practices. To that end, please identify the companies
with which you are engaged in benchmarking compensation and explain the extent
to which you benchmark total compensation or any material element of
compensation. Please refer to Item 401(b)(2)(xiv) of Regulation S-K.


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In future filings the Company will clarify the extent to which the Company
benchmarks total compensation or any material element of compensation.

We respectfully submit that the Company did on page 13 of the Proxy Statement
fully disclose the names of companies it used for benchmarking compensation for
its chief executive officer.

The Company intends to continue using general surveys for benchmarking its
executive compensation. These surveys may consist of data from several hundred
companies, such as the "general industry companies with data regressed based on
the Company's revenue size" and "industrial manufacturing companies with data
regressed based on the Company's revenue size" referenced on page 13 of the
Proxy Statement. In future years if the Company benchmarks off of general market
surveys, we respectfully submit that the identification of each company
contained in such surveys would not provide meaningful disclosure to the
Company's shareholders and would interfere with the goal of providing a concise
discussion of the Company's benchmarking practices. Instead, in that case the
Company would discuss the survey in general and the rationale behind selection
of such survey for benchmarking purposes. Of course, if the Company uses more
limited and targeted peer group data for benchmarking it will identify each
company included in such peer group.

7. Please disclose your target compensation and provide analysis of the reasons
for such target. While we note your disclosure that actual pay should and does
vary from these targets, your revised disclosure should address whether actual
compensation awarded was at the targeted amount and, if not, explain why it was
outside of the range.

In future filings the Company will clarify its disclosure of target compensation
and provide analysis of the reasons for such target, including whether actual
compensation awarded was at the targeted amount, and if not, an explanation of
why it was outside of the range.

Please be advised that for 2006, as noted on page 12 of the Proxy Statement, the
Company believes that to attract and retain qualified management, pay levels
(including base salary, incentive compensation (both long and short term) at
target, and benefits) should be targeted at the 50th percentile (or median) of
comparable positions within the general market for which it competes for labor.
Actual pay from year to year should and does vary from these targets based on
Company and individual performance with respect to short-term incentives and
changes in stock price over time for long-term incentives. In 2006, the
Compensation Committee reviewed each named executive officer's compensation and
adjusted such compensation as necessary so that targeted total compensation, as
well as each element of total compensation (salary, short and long-term
incentives and benefits) would be at the targeted 50th percentile (or median) of
the reference points on which the Company benchmarks compensation, as discussed
on page 13 of the Proxy Statement.

Long-Term Incentives, page 15

8. You indicate that the long-term incentive awards consist of awards of stock
options and awards of restricted stock. You also indicate that it is currently
structured to provide a 50/50 allocation of expected value between the two kinds
of awards. While we note that the actual award is based primarily on individual
performance and to a lesser extent, company


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performance, the basis for determining each component of long-term incentive
compensation is unclear. Please explain each factor of performance taken into
account to determine long-term incentive compensation. Address how these factors
are reflected in the determination of the amount of compensation including the
allocation of compensation between the different awards. Please refer to Item
402(b)(1)(v) of Regulation S-K.

In future filings the Company will clarify the basis for determining each
component of long-term incentive compensation.

Please be advised that, in 2006, Mr. Kingsley recommended to the Compensation
Committee the actual award level for each named executive officer, other than
himself. Mr. Kingsley's recommendation is based on his subjective discretionary
determination of the individual's performance and to a lesser extent his
subjective assessment of the Company's performance. The Compensation Committee,
however, ultimately determined each named executive officer's award level after
taking into account Mr. Kingsley's recommendations. Mr. Kingsley's award level
is determined by the Compensation Committee's subjective and discretionary
determination of his performance, and to a lesser extent their subjective view
of the Company's performance.

As described on page 15 of the Proxy Statement, long-term incentive awards for
the NEOs in 2006 were structured to provide 50% of the expected value in the
form of stock options and 50% of the expected value in the form of restricted
stock. The expected value is based on a Black-Scholes valuation of the Company's
common stock.

Summary Compensation Table, page 22

9. We refer you to Securities Act Release 8732A, Section II.B.1. As noted in
that section, the compensation discussion and analysis should be sufficiently
precise to identify material differences in compensation policies with respect
to individual named executive officers. In this regard, we note that Mr.
Kingsley's salary, non-equity incentive plan compensation and grants of options
and restricted stock units were significantly higher than amounts given to other
named executive officers. Please explain the reasons for the differences in the
amount of compensation awarded to the named executive officers.

We respectfully submit that the Compensation Discussion and Analysis contained
in the Proxy Statement already sufficiently identifies any material differences
in compensation policies with respect to any individual named executive officer.
For example, page 13 of the Proxy Statement discusses that Mr. Kingsley's
compensation is benchmarked against a different peer group than other named
executive officers, and pages 14 and 15 of the Proxy Statement discloses that
his bonus is determined under the Incentive Award Plan and not the MICP. Unless
already specifically discussed in the Compensation Discussion and Analysis
section of the Proxy Statement, there were no differences in the compensation
policies with respect to individual named executive officers in 2006.

Please be advised that the disparity in Mr. Kingsley's compensation to the other
named executive officers may in part reflect that the Company has historically
benchmarked his compensation to a different peer group than other officers and
not towards any internal pay equity standards.


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Accordingly, the amount of Mr. Kingsley's compensation is higher than the other
named executives, as it is reflective of the Compensation Committee's view of
the competitive market for chief executive officer services, and not because of
any other different compensation policies.

Pension Benefits, page 25

10. Please provide a textual narrative to follow the pension benefits table that
includes a description of any material factors necessary to understanding each
plan covered by the tabular disclosure. The narrative should also explain the
evaluation method and all material assumptions applied in quantifying the
present value of the current accrued benefit. Please refer to Instruction 2 to
Item 402(b)(2) and Item 402(b)(3) of Regulation S-K.

We respectfully submit that the evaluation method and all material assumptions
applied in quantifying the present value of the current accrued benefits were
disclosed in footnote 2 to the pension benefits table. In addition, pages 17 and
18 of the Proxy Statement fully describe the Company's pension benefits.
Accordingly in future filings the Company will either move this description to
follow the pension benefits table or provide a cross reference to such
disclosure.

11. Please provide a footnote quantifying the extent to which amounts reported
in the contributions and earnings columns are reported as compensation in the
last fiscal year and the amounts reported in the aggregate balance at last
fiscal year end previously were reported as compensation to the named executive
officer in the summary compensation table for previous years. Please refer to
the Instruction to Item 402(i)(2) of Regulation S-K.

We presume that this comment applies to the nonqualified deferred compensation
table on page 26 of the Proxy Statement, as the pension benefits table has no
contributions and earnings columns and Item 402(i)(2) of Regulation S-K applies
only to the nonqualified deferred compensation table.

Please note that for 2006, there were no amounts included in the contributions
and earnings columns which were reported as compensation in the last fiscal
year, and no amounts reported in the aggregate balance column were previously
reported as compensation to any named executive officer in the summary
compensation table. The Company respectfully submits that since no amounts were
reportable, that no footnote should be required. If applicable, the Company will
in future filings provide the required footnote.

12. Please consider disclosing the measure for calculating plan earnings, and
quantify the earnings measure applicable during the last fiscal year. Please
refer to Item 402(i)(3)(ii) of Regulation S-K.

We presume this comment applies to the nonqualified deferred compensation table
on page 26, and not the pension benefits table on page 25, since the
disclosure of plan earnings with respect to the pension benefits table is not
relevant because named executive officers' pension benefits are determined by a
formula and not by reference to plan earnings. Also Item 402(i)(3)(ii) of
Regulation S-K applies to the nonqualified deferred compensation table.
Accordingly, please see the Company's response under comment 13 below.

Nonqualified Deferred Compensation, page 26


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13. Please add a narrative following the nonqualified deferred compensation
table to explain the material factors necessary to understand each plan covered
by the tabular disclosure. While material factors vary depending upon the facts
consider discussion any plan based limitations, measures for calculating plan
earnings and material terms with respect to withdrawals and distributions.
Please refer to Item 402(i)(3) of Regulation S-K.

We respectfully submit that the measures for calculating plan earnings and all
other material terms of our non-qualified deferred compensation plans were
described in full on pages 17 -19 of the Proxy Statement. Accordingly, in future
filings the Company will either move this description to follow the nonqualified
deferred compensation table or provide a cross reference to such disclosure.

Potential Payments Upon Termination or Change in Control, page 26

14. In the compensation discussion and analysis section, please describe and
explain how the appropriate payment and benefit levels are determined under the
various circumstances that trigger payments or provision of benefits upon
termination or a change in control. Please refer to Items 402(b)(1)(v) and
402(j)(3) of Regulation S-K. Please discuss why you have chosen to pay various
multiples of the components of compensation as severance or change-in-control
payments and disclose the multiples of compensation that the cash severance
payments represent.

In future filings the Company will include in the compensation discussion and
analysis section a description of how the appropriate payment and benefit levels
were determined under the various circumstances that trigger payments or
provisions of benefits upon termination or a change in control, including a
discussion of why the Company has chosen to pay various multiples of the
components of compensation as severance or change-in-control payments and to
disclose the multiples of compensation that the cash severance payments
represent.

Please note that pages 26 and 27 of the Proxy Statement contain a description of
the severance benefits that each of the named executive officers would be
entitled. The severance benefits payable to Mr. Kingsley, Mr. Romeo and Ms. Bors
were the subject of negotiations with each individual at the time of his or her
hire and were deemed a necessary condition to hiring these individuals. The
level of each of Messrs. Kingsley's and Romeo's, and Ms. Bors' severance
benefits is reflective of the Company's perception of the market for their
positions, as was confirmed by Towers Perrin at the time of hire. In addition,
upon his promotion in 2005, Mr. Kingsley's severance was adjusted to include
100% of his bonus, rather than 75% as under his original contract. This
adjustment was intended to bring his severance in line with severance for chief
executive officers in general, including that which had been payable to Mr.
Williams prior to his departure. The agreements with Messrs. McMurray and Notaro
were put in place after they were already employed. Their agreements were
intended to provide a retention incentive, by alleviating any potential concern
about job loss in the event of a change in control. Again, the level of their
severance benefits was determined based on a general review of market practices
for these positions at the time.

Compensation of Directors, page 28


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15. Please include a footnote to the table that discloses the grant date fair
value of the equity awards, Please refer to Instruction to Item 402(k)(2)(iii)
and (iv) of Regulation S-K. In that footnote, you also should disclose the
aggregate number of stock awards outstanding at fiscal year end.

In future filings the Company will disclose in a footnote the aggregate number
of stock awards outstanding at fiscal year end. We respectfully submit that the
grant date fair value of the equity awards was included in footnote 2 to the
director's compensation table found on page 28 of the Proxy Disclosure.

16. Please revise the narrative that follows the director's compensation table
to describe the compensation arrangements for the directors, addressing whether
any director has a different compensation arrangement. Please refer to Item
402(k)(3) and the Instructions to Item 402(k) of Regulation S-K.

In future filings the Company will revise the narrative following the director's
compensation table to clarify the compensation arrangements for directors,
including addressing whether any director has a different compensation
arrangement either by moving the disclosure in footnote 1 to the director's
compensation table to the narrative discussion, or by cross referencing such
disclosure.

                                      * * *

IDEX Corporation acknowledges that it is responsible for the adequacy and
accuracy of the disclosure in its filing; staff comments or changes to
disclosure in response to comments do not foreclose the Commission from taking
any action with respect to the filing; and IDEX Corporation 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.

If you have any questions or comments in connection with this response please
call the undersigned at (847) 498-7070, or Christopher Lueking of Latham &
Watkins LLP at (312) 876-7680.

                                        Very truly yours,


                                        Frank Notaro
                                        Vice President, General Counsel and
                                        Secretary

cc: Lawrence D. Kingsley
    Christopher Lueking


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