SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

December 5, 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 November 9, 2005 response letter to
our
October 26, 2005 comment letter 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.

	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.

List of Consolidated Financial Statements and Financial Statement
Schedule, page F-1
Notes to Consolidated Financial Statements, page F-7

Note 1 - Business and Summary of Significant Accounting Policies,
page F-7

1.
Based on your response to prior comment one, it is still unclear
why
it is appropriate to estimate your contractual allowances using
the
reciprocal of the expected percentage that will be collected.
Based
on this and your previous response, 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.

Please clarify this for us and, in so doing, cite the specific
authoritative guidance that supports this.  In estimating amounts
that will not be collected, please justify why it is appropriate
for
you to apparently not distinguish between:  (a) contractual and
any
other billing adjustments, which apparently should have been
charged
against revenue, and (b) adjustments resulting from the inability
to
collect contracted amounts where collection had been reasonably
assured, which arguably should have been charged to bad debt
expense.

2. Please justify why it is appropriate to account for the final
settlements on a prospective basis, as described in your response
to
prior comment two.  In so doing, please cite the specific
authoritative guidance that supports not recognizing the final
settlements currently.  In addition, please note that the apparent
limited capabilities of your billing systems would not appear to
be
an appropriate justification for your accounting for the final
settlements.

Furthermore, please tell us the extent to which the final
settlements
result in you realizing less than the carrying amount of the
receivable and the extent to which you realize more.  Where you
realize less, please justify why not recognizing the difference
immediately upon final settlement complies with paragraphs 8, 22
and
23 of SFAS 5 and any other relevant guidance.  Finally, whether
you
realize less or more, please clarify how your net accounts
receivable
and revenue are not materially overstated or understated,
respectively.

3. Please tell us whether the change in the accounting estimate,
described in your response to prior comment five, was material.
If
so, please provide us disclosures that would have discussed the
impact of the change on your income statements, as recommended
under
paragraph 33 of 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.
December 5, 2005
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