November 18, 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 response and have the following additional
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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

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

(1) The Company and its Significant Accounting Policies
Sales Returns, page F-11

1.    We note your response to our comment number 2 from our letter dated
November 7, 2019
      and have the following additional comments:
        Explain why the asset for the right to recover product estimated to be
returned is
          netted against accounts receivable. In this regard, we note that ASC
606-10-55-23c
          requires a corresponding adjustment to cost of sales for the right to
recover product;
        Please reconcile your use of an allowance for sales returns given the
requirement to
          separately recognize a refund liability pursuant to ASC
606-10-55-23b; and
        Tell us the amounts you have recognized as assets for your rights to
recover product
          and refund liabilities for each of the periods presented and, if
material, address the
          guidance in ASC 606-10-55-27 regarding separate presentation of these
assets and
          liabilities.
 Russell Greenberg
INTER PARFUMS INC
November 18, 2019
Page 2

        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.

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



FirstName LastNameRussell Greenberg                       Sincerely,
Comapany NameINTER PARFUMS INC
                                                          Division of
Corporation Finance
November 18, 2019 Page 2                                  Office of Life
Sciences
FirstName LastName