November 7, 2019

Russell Greenberg
Chief Financial Officer
INTER PARFUMS INC
551 Fifth Avenue
New York, New York 10176

       Re: INTER PARFUMS INC
           Form 10-K for the year ended December 31, 2018
           Filed on March 1, 2019
           File No. 000-16469

Dear Mr. Greenberg:

       We have reviewed your registration statement and have the following
comments. In
some of our comments, we may ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form 10-K for the year ended December 31, 2018

(1) The Company and its Signifcant Accounting Policies
Revenue recognition, page F-11

1.     You recognize revenue from your contracts when contract terms are met,
the price is fixed
       and determinable, collectability is reasonably assured and product is
shipped or risk of
       ownership has been transferred to and accepted by the customer. It is
unclear how this
       policy complies with the provisions of ASC 606. Specifically, clarify
how
       you consider the transfer of control of your products when considering
the timing of
       revenue recognition. Refer to paragraphs ASC 606-10-25-23 through 25-26.
       Furthermore, tell us your consideration of the disclosures set forth in
ASC 606-10-50 (e.g.
       contract balances, remaining performance obligations, determining the
transaction price,
       including variable consideration, etc.)
 Russell Greenberg
INTER PARFUMS INC
November 7, 2019
Page 2
Sales Returns, page F-11

2.       Tell us whether you record an asset for the right to recover goods
from your customers.
         Please refer to ASC 606-10-55-23 .
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      You may contact Ameen Hamady at 202-551-3891, or in his absence, Jeanne
Baker at
202-551-3691 if you have questions.



FirstName LastNameRussell Greenberg                           Sincerely,
Comapany NameINTER PARFUMS INC
                                                              Division of
Corporation Finance
November 7, 2019 Page 2                                       Office of Life
Sciences
FirstName LastName