October 25, 2004

Mail Stop 0409

VIA U.S. MAIL AND FAX (603) 335-2834

Mr. James F. Brooks
Chief Executive Officer and President
BrandPartners Group, Inc.
10 Main Street
Rochester, NH 03839

RE:	BrandPartners Group, Inc.
	Form 8-K filed October 22, 2004
            File No. 0-16530

Dear Mr. Brooks:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, 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.

1. Amend the report to include the required letter from the former
accountant.  See Item 4 of Form 8-K and Item 304 of Regulation S-K.
File the amendment under cover of Form 8-KA and include the ITEM 4.01
designation, including the letter from the former accountant filed as
an Exhibit 16.

2. When you engage a new accountant, please report the engagement in
a new Form 8-K and comply with the requirements of Regulation S-K
Item 304 (a)(2).  In making any disclosures about consultations with
your new accountants, please ensure you disclose any consultations up
through the date of engagement.

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.  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 in the filings reviewed by the staff 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 provide the supplemental information requested above within 10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The
amendment requested should be filed as promptly as possible and
should be reviewed by the former accountants.  The letter required by
Exhibit 16 should cover the revised disclosures. Please note that
your former accountants should make it clear within the Exhibit 16
letter that it is in reference to your amended Form 8-K.

You may reach me at (202) 824-5336 with any questions.

						Sincerely,



						Rachel Zablow
						Staff Accountant


BrandPartners Group, Inc.
October 25, 2004



Page 1