Exhibit 10.7

A.T. Cross Company
Incentive Compensation Plan - 2005

Introduction

Performance Measures

The corporate incentive pool is created when certain levels of OIBT and net sales are achieved.  The individual incentive pool is created when any individual objective is achieved.  Based on the level of achievement, and considering the funding matrix, the pool will be created by multiplying the corporate payout multiple from the matrix for the achievement level by the base pay of participants and then by the target bonus level of participants.

|Corporate Incentive Pool =
Base Pay of Participants X Target Awards of Participants X Weighting of
Corporate Segment of Participants X Payout Multiple
Example Only
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------
|                                                                                                                                                                   
|                                                                                                                                                                   
|                                                                                                                                                                   
|Pre-Bonus                                                                                                                                                          
|OIBT                                                                                                                                                               
|Achievement                                                                                                                                                        
|of Plan                                                                                                                                                            

Each individual objective will be evaluated on the following scale.

| | Modifier for Achievement of Individual Objectives
| | -------------------------------------------------
| |                                                  
| | Objective Rating                                 
| | Did Not Achieve                                  
| | Achieved Most Results                            
| | Achieved All Results                             
| | Exceeded Some Results                            
| | Exceeded All                                     

The Exceeded All rating will be reserved for use by the President/CEO and responsible Vice President.  The ratings on each objective will be multiplied by the cash value of the individual objective and then totaled to calculate the individual objective bonus amount.

Eligibility

Target Bonus Levels

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| |         | Base Salary Range ($000) | Incentive Target Salary
(as a % of base)
| | ------- | ------------------------ | ----------------------------------------
| |         |                          |                                         
| | Level A | $170 - $250              | 35%                                     
| | Level B | $130 - $170              | 25%                                     
| | Level C | $100 - $130              | 20%                                     
| | Level D | $80 - $100               | 15%                                     
| | Level E | $60 - $80                | 10%                                     

Payout of Plan Awards

Changes in Employment Status

Disability or Death

Administration

Participation in this Plan does not confer any right to continued employment by A. T. Cross.  Similarly, selection for participation in any one year does not necessarily guarantee participation in future years.  No member of the Compensation Committee shall have any personal liability in connection with the administration of the Plan.

Definitions

Operating Income Before Taxes (OIBT)

Net Sales

Corporate Targets

International Calculations

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