SecProbe.io

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             [Skadden, Arps, Slate, Meagher & Flom LLP Letterhead]

                                                  July 7, 2005

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Pamela W. Carmody, Esq.

VIA Facsimile and EDGAR Correspondence

         Re:  Mylan Laboratories Inc.
              Schedule TO-I filed on June 16, 2005
              File No. 005-10728

Dear Ms. Carmody:

         On behalf of our client, Mylan Laboratories Inc., a Pennsylvania
corporation (the "Company" or "Mylan"), we provide the following responses in
connection with the comments of the staff (the "Staff") of the Securities and
Exchange Commission (the "Commission) regarding the Schedule TO-I filed on
June 16, 2005 by Mylan, contained in your letter dated June 29, 2005 (the
"Comment Letter"). The numbered paragraphs below correspond to the numbered
paragraphs in the Comment Letter.

Schedule TO-I
-------------

1.       We note that the company has offset the filing fee with the fee paid
         in connection with the company's registration statement on Form S-4
         filed on September 3, 2004. Rule 0-11(a)(2) provides for offsetting
         fees when the filings are related to one transaction. It is unclear
         how the Form S-4 relates to this transaction. Please advise.

         Company Response: As discussed by telephone with the Staff on July 1
         and July 6, 2005, Mylan had filed a Form S-4 (File No. 333-118828) in
         September 2004, and after terminating the merger to which it related
         in February 2005, Mylan withdrew the registration statement in June
         2005. Pursuant to Securities Act Rule 457(p), the Company was aware
         that following withdrawal of a registration statement, the filing fee
         associated with the related unsold securities could be offset against
         filing fees due for a subsequent registration statement if certain
         conditions set forth in such rule were met. Kristin A. Kolesar, Esq.,
         Corporate Counsel for Mylan, contacted the EDGAR Filing Support
         Department of the Commission by telephone on June 15, 2005 and, after
         a brief description of the inquiry, was transferred to someone who
         could assist with regard to the funds in the Company's SEC account.
         Ms. Kolesar then explained to the gentlemen who took the call (whose
         name was not provided to her) that Mylan had filed a Form S-4
         relating to a merger that was later terminated, that Mylan recently
         had withdrawn the Form S-4 relating thereto and that Mylan was
         planning to file a Schedule TO relating to a self-tender on June 16,
         2005. Ms. Kolesar asked the gentleman whether a portion of the unused
         fee paid on such Form S-4 could be used for the fee that would be
         payable upon filing the Schedule TO. The gentleman, after accessing
         Mylan's account information, advised Ms. Kolesar that an offset was
         permitted and, in response to Ms. Kolesar's inquiry, described to her
         how to complete the "offset box" on the cover of Schedule TO. Mylan
         followed such instructions when completing the cover of Schedule TO,
         and then filed the Schedule TO on June 16, 2005. The filing was
         accepted (and in fact, was not rejected on the basis of non-payment
         of the required fee).

Offer to Purchase
-----------------

2.       It is our position that a material change in the offer occurs when
         the offer becomes financed, e.g., financing is obtained or the
         financing condition is otherwise satisfied, and that, accordingly,
         five days must remain in the offer or the offer must be extended upon
         the satisfaction of the financing condition. Please advise of your
         intent in this regard. We note that the offer is contingent on the
         receipt of financing on terms satisfactory to Mylan. We may have
         further comment.

         Company Response: Pursuant to our discussion by telephone with the
         Staff on July 1 and July 6, 2005, Mylan intends to make the following
         statement on an Amendment to Schedule TO to be filed at least five
         business days prior to the expiration of the Offer:

         "As disclosed in the Offer to Purchase (as defined in Schedule TO
         filed on June 16, 2005), Mylan Laboratories Inc. ("Mylan" or the
         "Company") obtained a commitment letter from Merrill Lynch Capital
         Corporation and Merrill Lynch, Pierce, Fenner & Smith Incorporated,
         pursuant to which Merrill Lynch Capital committed to provide Mylan
         with a $975 million credit facility. Mylan is continuing to arrange
         financing in connection with the Offer. One of the conditions to the
         Company's obligation to purchase its common stock in the Offer is
         that Mylan has obtained or is able to obtain, prior to the expiration
         date of the Offer, financing (a) pursuant to the terms and conditions
         of such commitment letter and (b) on terms reasonably satisfactory to
         the Company, which, with existing cash reserves, will be sufficient
         to consummate the Offer. The Company today is waiving the portion of
         such condition that requires the financing to be on terms reasonably
         satisfactory to the Company. Therefore, this condition is restated as
         follows:

         'Notwithstanding any other provision of the Offer, Mylan will not be
         required to accept for payment, purchase or pay for any Shares
         tendered, and may terminate or amend the Offer or may postpone the
         acceptance for payment of, or the purchase of and the payment for
         Shares tendered, subject to the rules under the Exchange Act, if at
         any time on or after the commencement of the Offer and before the
         Expiration Date any of the following events have occurred (or have
         been determined by Mylan to have occurred) that, in the Company's
         reasonable judgment and regardless of the circumstances giving rise
         to the event or events (other than any action or omission to act by
         Mylan), makes it inadvisable to proceed with the Offer or with
         acceptance for payment:

            o     Mylan is or will be unable prior to the Expiration Date to
                  obtain financing pursuant to the terms and conditions
                  contained in the Commitment Letter described in Section 9,
                  which, with existing cash reserves, will be sufficient to
                  purchase the Shares pursuant to the Offer and pay related
                  fees and expenses.'

         Other conditions of the Offer remain unchanged. Capitalized terms
         used, but not defined, in this Amendment shall have the meaning set
         forth in the Offer to Purchase filed as Exhibit (a)(1)(A) to Schedule
         TO on June 16, 2005."

         The Offer currently is scheduled to expire at 5:00 p.m. New York City
         time on Friday, July 15, 2005. The Company likely will file an
         Amendment to the Schedule TO on Monday, July 11, 2005 including the
         information set forth above, and in that Amendment (and by press
         release) extend the Offer until midnight on July 15, 2005, so that
         the Offer is open for five business days following the dissemination
         of the information set forth above.

Annex A
-------

3.       Statements made in connection with tender offers are expressly
         excluded from the safe harbor protections afforded by the Private
         Securities Litigation Reform Act of 1995. Accordingly, please refrain
         from references to the safe harbor in future communications.

         Company Response: The Company will comply with the Staff's comment in
         future communications.

                                     * * *

         In addition, in response to the Staff's request, enclosed is an
acknowledgment letter from Edward J. Borkowski, Chief Financial Officer, of
the Company.

                                     * * *

         Please telephone the undersigned at (212) 735-3207 or Eric L. Cochran
of this firm at (212) 735-2596 if you have any questions or need any
additional information.

                                                     Very truly yours,

                                                     /s/ MARIE L. GIBSON

                                                     Marie L. Gibson

cc:    Stuart A. Williams, Esq.
       Kristin A. Kolesar, Esq.

<PAGE>

                            Mylan Laboratories Inc.
                             1500 Corporate Drive
                        Canonsburg, Pennsylvania 15317
                               Tel: 724.514.1800
                               Fax: 724.514.1870

July 7, 2005

Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Attn: Pamela W. Carmody

RE:   Mylan Laboratories Inc., Schedule TO-I, filed on June 16, 2005,
      File No. 005-10728
      ---------------------------------------------------------------

Dear Ms. Carmody:

In response to the request of the staff of the Securities and Exchange
Commission (the "Commission") set forth in the staff's letter sent June 29,
2005, Mylan Laboratories Inc. (the "Company") hereby acknowledges that:

          (a)  the Company is responsible for the adequacy and accuracy of the
               disclosure in the filing of its Schedule TO and any amendment
               thereto;

          (b)  staff comments or changes to disclosure in response to staff
               comments do not foreclose the Commission from taking any action
               with respect to the filing; and

          (c)  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.

MYLAN LABORATORIES INC.

By   /s/ EDWARD J. BORKOWSKI
     ----------------------------
    Edward J. Borkowski
    Chief Financial Officer
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