August 30, 2006

Via U.S. Mail and Facsimile

Efraim Grinberg
Chief Executive Officer
Movado Group, Inc.
650 From Road
Paramus, New Jersey 07652



RE:		Movado Group, Inc.
		Form 10-K for the fiscal year ended January 31, 2006
		Form 10-Q for the fiscal quarter ended April 30, 2006
		File No. 1-16497

Dear Mr. Grinberg:

      We have limited our review of your Form 10-K for the fiscal
year ended January 31, 2006, and your Form 10-Q for the fiscal
quarter ended April 30, 2006, to disclosures relating to your
contacts with countries that have been identified as state
sponsors
of terrorism.  Our review with respect to this issue does not
preclude further review by the Assistant Director group with
respect
to other issues.  At this juncture, we are asking you to provide
us
with supplemental information, so that we may better understand
your
disclosure.  Please be as detailed as necessary in your response.
After reviewing this information, we may 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
filings.
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.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


General -

1. We note that your website lists "Movado Service Center
locations
outside the continental United States" including service centers
in
Iran and Syria.  Your 10-K included no information regarding
contacts
with Iran and Syria. We also note that Exhibit 10.1 to your 10-Q
for
the quarterly period ended April 30, 2006, is a licensing
agreement
granting a license to your subsidiary covering territory which
includes Cuba, Iran, North Korea, Sudan and Syria.  The licensing
agreement also identifies relevant trademarks in Cuba, Iran, North
Korea, Sudan and Syria.

In light of the fact that Cuba, Iran, North Korea, Sudan and Syria
have been identified by the U.S. State Department as state
sponsors
of terrorism, and are subject to U.S. economic sanctions, please
describe for us the extent and nature of any past, current, and
anticipated contacts with those countries, whether through
subsidiaries, affiliated entities, independent distributors or
through other direct or indirect arrangements.

2. Discuss for us the materiality to you of any contacts with
Cuba,
Iran, North Korea, Sudan and Syria, individually and in the
aggregate, and whether those contacts, individually or in the
aggregate, constitute a material investment risk for your security
holders.  Please address materiality in quantitative terms,
including
the dollar amounts of any associated assets and liabilities, and
revenues.  Please also address materiality in terms of qualitative
factors that a reasonable investor would deem important in making
an
investment decision, including the potential impact of corporate
activities upon consumer sentiment and on a company`s reputation
and
share value.

We note, for example, that Arizona and Louisiana have adopted
legislation that requires their state retirement systems to
prepare
reports regarding state pension fund assets invested in, and/or
permits divestment of state pension fund assets from, companies
that
do business with U.S.-designated state sponsors of terrorism.  The
Pennsylvania legislature has adopted a resolution directing its
Legislative Budget and Finance Committee to report annually to the
General Assembly regarding state funds invested in companies that
have ties to terrorist-sponsoring countries.  Illinois, Maine, New
Jersey and Oregon have adopted legislation requiring reporting of
interests in, or divestment from, companies that do business with
Sudan, and similar legislation has been proposed by several other
states.  Florida requires that issuers disclose in their
prospectuses
any business contacts with Cuba or persons located in Cuba.
Harvard
University, Yale University, Stanford University, and other
educational institutions have adopted policies prohibiting
investment
in, and/or requiring divestment from, companies that do business
with
Sudan.  Your materiality analysis should address the potential
impact
of the investor sentiment evidenced by such actions directed
toward
companies that operate in Cuba, Iran, North Korea, Sudan and
Syria.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, 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
do not foreclose the Commission from taking any action with
respect
to the filings; 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 filings or in response
to
our comments on your filings.



      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk



cc: 	Chris H. Owings
		James Allegretto
		David Mittelman
		Division of Corporation Finance

Efraim Grinberg
Movado Group, Inc.
August 30, 2006
Page 1









UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE