Securities and Exchange Commission
Mail Stop 3561
CF/AD11
100 F St. NE
Washington, DC 20549-3561

									October 20, 2005


Mr. Maurice Levy
Chief Executive Officer and
Chairman of the Management Board
Publicis Groupe S.A.
133, Avenue Des Champs-Elysees
75008 Paris, France

	Re:	Publicis Groupe S.A.
      Form 20-F for Fiscal Year Ended December 31, 2004
      Filed June 24, 2005
		File No. 1-14736

Dear Mr. Levy:

      We have reviewed your supplemental response letter dated
September 15, 2005 and have the following comments.  As noted in
our
comment letter dated August 23, 2005, we have limited our review
to
only the issues addressed in our comments.

Form 20-F
Financial Statements
31. Summary of differences between generally accepted accounting
principles in France and the United States, page F-47

1. We note you recognize revenue from production arrangements as
the
service is preformed, based on time spent as compared to time
budgeted.  It appears, for US GAAP reporting purposes, revenue
from
production arrangements should be recognized when delivery has
occurred pursuant to SAB Topic 13.A.1. and paragraph .07 of SOP
00-2.
Please refer us to the US GAAP literature that supports your use
of
the percentage of completion method and explain to us why it is
appropriate to recognize revenue under this guidance rather than
upon
delivery in accordance with SAB Topic 13 and SOP 00-2.

Segment Information, page F-78

2. We note in your response to comment 3 that your monthly
internal
reporting is organized in eight separately identified brands.  You
believe your brands do not meet the SFAS No. 131 definition of an
operating segment.  Regarding your assessment of whether the
characteristics of an operating segment are present with your
organization by brands, you confirm that all of your brands engage
in
business activities from which it may earn revenues and incur
expenses, and discrete financial information is available.
However,
you have asserted that the allocation of resources made by
Publicis
Groupe`s Chief Operating Decision Maker ("CODM") is not based on
this
organization but is based on a global allocation between
advertising
and media.

3. Because brand based operating information is made available to
your CODM, we presume he reviews it when making decisions about
resource allocations and when assessing performance.  As further
support for this view, we note your CODM prepares and analyzes
detailed monthly and year-to-date budget information for each of
your
eight brands.  Also, it appears your CODM has made material
resource
allocation decisions and performance assessments using brand based
information such as in the reorganization of the Group and the
goodwill impairment decisions recently made by your CODM.  We
request
that you revise your policy to identify your brands as operating
segments.  Please confirm this to us and explain how this has
impacted you compliance with SFAS No. 131 and SFAS No. 142 for US
GAAP reporting purposes.

4. Further, the first two paragraphs of page 6 of your letter
suggests to us that the natures of the production processes,
products
and services of  Publicis Groupe Media  may differ from that of
your
traditional advertising operations.   Further, Appendix 1 to your
response indicates that revenues and operating income for  Starcom
MediaVest Group and ZenithOptimedia Group exceed the 10% reporting
thresholds of paragraph 18 SFAS 131.  Describe the natures of the
production processes, products and services of SMG +
ZenithOptimediaGroup.  Compare and contrast those production
processes, products and services of SMG + ZenithOptimediaGroup
with
those of your traditional advertising operations and explain to us
your consideration of the aggregation criteria of paragraph 17 of
SFAS 131 and why the SMG + ZenithOptimediaGroup operating segment
is
not reported separately.











*    *    *    *







      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  You may contact
Joseph M. Kempf, Senior Staff Accountant, at (202) 551-3352 or
Robert
S. Littlepage, Accountant Branch Chief, at (202) 551-3361 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3810 with any other
questions.

								Sincerely,



								Larry Spirgel
								Assistant Director

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Mr. Maurice Levy
Chief Executive Officer and Chairman of the Management Board
Publicis Groupe S.A.
October 20, 2005
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