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January 24, 2005

    BY FACSIMILE TO (202) 942-9627

    Edward G. Quinlisk

Tel 312 840-8679

Fax 312 840-8779

equinlisk@jenner.com

United States Securities and Exchange Commission

Division of Corporate Finance

450 Fifth Street, N.W.

Washington, DC 20549-0306

    Attention:

    Edward M. Kelly

Nudrat S. Salik

    Re:

    Viskase Companies, Inc.

Registration Statement on Form S-4

File 333-120002

Ladies and Gentlemen:

            On behalf of Viskase Companies, Inc. (the “Company”), we are further responding to your
comment letter of January 11, 2005 regarding the above-referenced registration statement.

            Set forth below is a supplemental response of the Company to comment 25 in your letter, which
we had previously indicated was in process.

•           Comment 25: We note in your response to prior comment 74. Tell us where you have
provided the disclosures required by paragraphs 5(d), 5(f), and 9(a) of SFAS 132R.

            Response The disclosures required by 5(d), 5(f) and 9(a) of SFAS 132® are located
on pages 52, F-29 and F-29 respectively. Revised pages 52 and F-29 are attached hereto.

    Very truly yours,

    /s/ Edward G. Quinlisk

    Edward G. Quinlisk

EGQ: jeo

cc: Gordon S. Donovan

high quality corporate bonds as of the valuation
date. Our funding policy is consistent with funding requirements
of the applicable federal and foreign laws and regulations.

Our North American operations have postretirement
health care and life insurance benefits. We accrue for the
accumulated postretirement benefit obligation that represents
the actuarial present value of the anticipated benefits.
Measurement is based on assumptions regarding such items as the
expected cost of providing future benefits and any cost sharing
provisions. The Company will terminate postretirement medical
benefits as of December 31, 2004 for all active employees
and retirees in the U.S. who are not covered by a
collective bargaining agreement. It is estimated that said
termination will result in a $35 million reduction in the
Company’s unfunded postretirement liability.

The weighted average plan asset allocation at
December 31, 2003 and 2002, and target allocation (not
weighted) for 2004, are as follows:

    Percentage of Plan

    Assets

    2004

    Target

    Asset Category

    2003

    2002

    Allocation

    Equity Securities

    58.5
    %

    52.7
    %

    60
    %

    Debt Securities

    37.1
    %

    45.4
    %

    40
    %

    Other

    4.4
    %

    1.9
    %

    0
    %

    Total

    100
    %

    100
    %

As of January 1, 2004, we have assumed that
the expected long-term rate of return on plan assets will
be           %.
This represents a decrease from
the           %
level assumed for 2003
and           %
level assumed for 2002. To develop the expected long-term rate
of return on assets and assumptions, we considered historical
returns and future expectations.

    Fresh-Start Accounting

As previously discussed, the accompanying
consolidated financial statements reflect the use of fresh-start
accounting as required by SOP 90-7. Under fresh-start
accounting, our assets and liabilities were adjusted to fair
values and a reorganization value for the entity was determined
based upon the estimated fair value of the enterprise before
considering values allocated to debt. The portion of the
reorganization value that could not be attributed to specific
tangible or identified intangible assets of the Reorganized
Company totaled $44.4 million. In accordance with Statement
of Financial Accounting Standards (SFAS) No. 142,
“Goodwill and Other Intangible Assets,” this amount is
reported as “Goodwill” in the consolidated financial
statements. Fresh-start accounting results in the creation of a
new reporting entity with no accumulated deficit as of
April 3, 2003. Our reorganization value was based on the
consideration of many factors and various valuation methods,
including discounted cash flow analysis using projected
financial information, selected publicly traded company market
multiples of certain companies operating businesses viewed to be
similar to us, and other applicable ratios and valuation
techniques believed by us to be representative of our business
and industry.

The valuation was based upon a number of
estimates and assumptions, which are inherently subject to
significant uncertainties and contingencies beyond our control.

Upon the adoption of fresh-start accounting, as
of April 3, 2003, we recorded goodwill of
$44.4 million, which equals the reorganization value in
excess of amounts allocable to identifiable net assets recorded
in accordance with SOP 90-7. In the fourth quarter of 2003,
we performed our first annual goodwill impairment analysis under
SFAS No. 142. Due to the fact the fair value of our
single reporting unit, as estimated by our market
capitalization, was significantly less than the net book value
at December 31, 2003, we wrote off the entire
$44.4 million goodwill balance in the fourth quarter of
2003.

52

VISKASE COMPANIES, INC. AND
SUBSIDIARIES

NOTES TO CONSOLIDATED FINANCIAL
STATEMENTS — (Continued)

    Pension Benefits

    Predecessor Company

    Reorganized

    Company

    January 1

    April 3

    Through

    Through

    April 2,

    December 31,

    2001

    2002

    2003

    2003

    Component of net period benefit cost

    Service cost

    $
    1,806

    $
    1,924

    $
    545

    $
    1,556

    Interest cost

    7,347

    7,522

    1,872

    5,634

    Expected return on plan assets

    (8,627
    )

    (7,686
    )

    (1,396
    )

    (4,585
    )

    Amortization of net pension obligation

    —

    —

    —

    —

    Amortization of prior service cost

    67

    56

    14

    144

    Amortization of actuarial (gain) loss

    91

    463

    532

    —

    Net periodic benefit cost

    684

    2,279

    1,567

    2,749

    One-time recognition of unamortized balance

    —

    —

    38,376

    —

    Total net periodic benefit cost

    $
    684

    $
    2,279

    $
    39,943

    $
    2,749

Upon emergence from bankruptcy, the liabilities
of the plans were remeasured as of April 2, 2003. A
one-time charge of $38,376 was recorded to immediately recognize
all unrecognized gains and losses.

The following table provides a summary of the
estimated benefit payments for the pension plans for the next
five fiscal years individually and for the following five fiscal
years in aggregate.

    Year

    Total Estimated Benefit Payments

    (in millions)

    2005

    $
    7.3

    2006

    7.3

    2007

    7.3

    2008

    7.4

    2009

    7.5

    2010-2014

    39.9

    Other Benefits

    Predecessor Company

    Reorganized

    Company

    January 1

    April 3

    Through

    Through

    April 2,

    December 31,

    2001

    2002

    2003

    2003

    Component of net period benefit cost

    Service cost

    $
    762

    $
    777

    $
    227

    $
    709

    Interest cost

    3,021

    3,270

    837

    2,585

    Expected return on plan assets

    —

    —

    —

    —

    Amortization of net pension obligation

    —

    —

    —

    —

    Amortization of prior service cost

    —

    —

    —

    141

    Amortization of actuarial (gain) loss

    136

    363

    112

    —

    Net periodic benefit cost

    3,919

    4,410

    1,176

    3,435

    One-time recognition of unamortized balance

    —

    —

    10,627

    —

    Total net periodic benefit cost

    $
    3,919

    $
    4,410

    $
    11,803

    $
    3,435

F-29