SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

October 26, 2005

Mr. Barry W. Weiner
President, Chief Financial Officer, and Director
Enzo Biochem, Inc.
60 Executive Boulevard
Farmingdale, NY  11735

Re:	Enzo Biochem, Inc.
	Form 10-K for the fiscal year ended July 31, 2004
	Filed October 14, 2004
	File No. 001-09974

Dear Mr. Weiner:

      We have reviewed your response dated July 8, 2005 to our
comment letter dated June 16, 2005 and have the following
comments.
In our comments, we have asked you to provide us with information
so
we may better understand your disclosure.  After reviewing this
information, we may raise additional comments.  In some of our
comments, we refer to your Form 10-K for the fiscal year ended
July
31, 2005.  Please note that we did not review that Form 10-K, but
looked at it solely in assessing your responses to our prior
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and ..., page 27

Critical Accounting Policies, page 29

1. Please tell us why it is appropriate to estimate your
contractual
allowances using the reciprocal percentage of the expected
percentage
that will be collected, as you described in your response to part
a.
of our prior comment one.  Based on this, it would appear that
your
estimate of contractual allowances includes all amounts that you
do
not expect to collect, even if some of those amounts go
uncollected
for reasons other than contractual allowances.  In addition,
please
tell us how this affects how you estimate your allowance for
doubtful
accounts.  Finally, as you responded that you use historical
reimbursement statistics, please tell us whether and how you
consider
changes in your payer mix.

2. As we did not note this in your response to part a. of our
prior
comment one, for each of the last three fiscal years, please
provide
us disclosures that would have quantified the amount of changes in
estimates of prior period contractual adjustments that you
recorded
during the current period.  For example, for fiscal 2005 , this
amount would represent the amount of the difference between
estimates
of contractual adjustments for services provided in fiscal 2004
and
the amount of the new estimate or settlement amount that was
recorded
during fiscal 2005.  If your billing system does not have the
capacity to provide this information, please provide us
disclosures
that would have stated this fact and that would have clarified how
this affects your ability to estimate your contractual allowances.

3. Please tell us whether the 1% change in the contractual
allowance
percentage, discussed in your response to part b. of our prior
comment one, represents what you believe to be a reasonably likely
change in your estimate, as contemplated by Section V. of
Financial
Reporting Release 72.  If not, please provide us with disclosures
that would address reasonably likely changes in your estimate.  In
addition, please tell us why the effect of this 1% change as of
and
for the fiscal year ended July 31, 2004 included in your response
is
different than the effect disclosed on page 30 of your Form 10-K
for
fiscal 2005.

4. We noted that you disclose "gross billing percentages by
billing
category" on page 29 of your Form 10-K for fiscal 2005.  Please
tell
us why you did not appear to provide this information on a net
basis,
which would appear to be the basis upon which the amounts should
be
reflected in your financial statements.  In addition, please
clarify
whether these amounts reflect the billings made during the year or
the billings outstanding as of the end of the year.  If these
amounts
reflect the billings outstanding, please tell us why the amounts
for
some categories for fiscal 2004 do not appear to be consistent
with
the amounts reflected in Table 2 to your response to part c. of
our
prior comment one.  If they reflect billings made during the year,
please tell us why it would not be appropriate to also disclose
the
amount of receivables by billing category.

5. According to your responses to prior comments two and four, you
wrote off all accounts receivable over 300 days.  However, on page
30
of your Form 10-K for fiscal 2005, you disclosed that, in fiscal
2005, you wrote off all accounts receivable over 210 days.  Please
tell us why this changed and explain whether the change is a
change
in estimate or a correction of an error, as contemplated by APB
20.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provide the
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.

      You may contact Tabatha Akins, Staff Accountant, at (202)
551-
3658 or Oscar Young, Senior Staff Accountant, at (202) 551-3622 if
you have questions regarding the comments.  Please contact me at
(202) 551-3679 with any other questions.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief
Accountant
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Barry W. Weiner
Enzo Biochem, Inc.
October 26, 2005
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