December 21, 2007



VIA OVERNIGHT DELIVERY
AND FACSIMILE (202) 772-9202

Ms. Hanna T. Teshome, Special Counsel
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010

Mail Stop: 3561

Re:  IDEX Corporation Response to Comment Letter dated December 7, 2007
     Definitive 14A Proxy Statement filed March 7, 2007 ("Proxy Statement")
     File No. 001-10235

Dear Ms. Teshome:

The following represents IDEX Corporation's (the "Company") response to the
additional comments of the staff of the Division of Corporation Finance in your
letter, dated December 7, 2007, to Mr. Lawrence D. Kingsley with respect to the
Company's Proxy Statement. For ease of reference each comment is repeated in
italics below and followed by the Company's response.

1. While we note your response to prior comment 6, we re-issue that comment in
part. Please confirm that you will identify the companies with which you
benchmark compensation. Please refer to Item 402(b)(2)(xiv) of Regulation S-K.

In reviewing market data, the Compensation Committee does not receive or
consider information with respect to pay practices of any individual company;
rather from time to time it has compared its compensation to general
compensation surveys such as the "general industry companies with data regressed
based on the Company's revenue size" and "industrial manufacturing companies
with data regressed based on the Company's revenue size" referenced on page 13
of the Proxy Statement. The Compensation Committee has relied only upon
aggregated data provided by general compensation surveys. The Company,
accordingly, has not benchmarked to the individual companies set forth in the
surveys, but rather only references the composite aggregated data of the
surveys.



In future filings, to the extent that the Company relies upon general market
surveys, we will disclose such surveys. To the extent that the Company
benchmarks against individual companies, the Company will identify in future
filings all individual companies with which we benchmark.

2. You also indicate in your response to our prior comment 9 that Mr. Kingsley's
compensation is benchmarked to a different peer group than other officers.
Please confirm that you will identify different peer groups against whom you
benchmark compensation for all named executive officers. In addition, please
confirm that you will disclose where you target each element of compensation
against the peer groups and where actual payments fall within targeted
parameters. To the extent actual compensation is outside a targeted percentile
range, please confirm that you will explain why.

In future filings the Company will identify, if applicable, different peer
groups against which we benchmark compensation for each named executive officer.
Please note that for 2006 the Company did on page 13 of Proxy Statement identify
the peer group that the Company used for benchmarking Mr. Kingsley's
compensation and, as discussed above, the surveys by which it compares all other
named executive officers' compensation. For 2007, the Company only used the
general survey data for purposes of determining the competitive nature of its
compensation package and did not use a separate peer group for Mr. Kingsley.

In addition, the Company will in future filings disclose where it targets each
element of compensation against any benchmarked peer groups or survey data and
where actual payments fell within targeted parameters, including an explanation
of any compensation outside the targeted percentile range. For 2006, please note
that on page 12 of the Proxy Statement, the Company has identified that pay
levels (including base salary, incentive compensation at target and benefits,
are targeted around the 50th percentile of the pay levels of comparable
positions at comparable companies based on the survey data and, for the CEO, his
benchmarked peer group. Generally, pay levels within 20% plus or minus of the
median are considered to be within the targeted range. In the aggregate, pay
levels for the named executive officers, other than Mr. Kingsley, were 2% below
the median, and each individual named executive officer was within 15% plus or
minus of the median in the survey data. Mr. Kingsley's actual total compensation
was 15% above the 50th percentile of pay levels for his benchmarked peer group.
Accordingly, we consider each individual named executive officer's actual total
compensation for 2006 to be within the targeted range.

                                  *     *     *

IDEX Corporation acknowledges that it is responsible for the adequacy and
accuracy of the disclosure in its filing; staff comments or changes to
disclosure in response to comments do not foreclose the Commission from taking
any action with respect to the filing; and IDEX Corporation 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.

If you have any questions or comments in connection with this response please
call the undersigned at (847) 498-7070, or Christopher Lueking of Latham &
Watkins LLP at (312) 876-7680.

                                             Very truly yours,

                                             /s/ Frank Notaro

                                             Frank Notaro
                                             Vice President, General Counsel
                                             and Secretary

cc:  Lawrence D. Kingsley
     Christopher Lueking


                                        2