The quantum Hall system is known to have two mutually dual Chern-Simons descriptions, one associated with the hydrodynamics of the electron fluid, and another associated with the statistics. Recently, Susskind has made the claim that the hydrodynamic Chern-Simons theory should be considered to have a non-commutative gauge symmetry. The statistical Chern-Simons theory has a perturbative momentum expansion. In this paper, we study this perturbation theory and show that the effective action, although commutative at leading order, is non-commutative. This conclusion is arrived at through a careful study of the three-point function of ChernSimons gauge fields. The non-commutative gauge symmetry of this system is thus a quantum symmetry, which we show can only be fully realized only through the inclusion of all orders in perturbation theory. We discuss the duality between the two non-commutative descriptions.