SecProbe.io

February 13, 2020

Kai Haakon E. Liekefett, Esq.
Sidley Austin LLP
787 Seventh Avenue
New York, NY 10019

Re: Enzo Biochem , Inc .
Preliminary Proxy Statement filed on February 11 , 2020
File No. 001-09974

Dear M r. Liekefett :

We have reviewed the above filing and related response letter and have the following
comments.

1. We note your response to prior comment 1 . We reissue the po rtion of the comment
requesting a description of the procedural requirements to postpone an annual meeting .

2. In addition , please confirm in your response letter that if quorum  had been established at
the January 31 meeting, the Board co uld still have adjourned the me eting over the
objection  of holders of the majority of shares present in person or by proxy or a majority
of shares of the voting stock outstanding.  In responding to this portion of the comment ,
please address NY BCL section 608(d) , In re Dollinger Corp., 274 N.Y.S.2d 285, 287
(N.Y. Sup Ct. 1966)( “It is the shareholders ’ meeting, the owners of the company, who
have the right to make a decision on a question of adjournment , and not of the president
who has only the duty of presiding .”) and Article 1, Section 6 of the By -Laws , including
the penultimate sentence thereto (“[i]n the absence of a quorum, the holders of a majority
of the votes of the shares of stock present in person or by proxy and entitled to  vote, or if
no shareholder entitled to vote is present, then any officer of the Corporation may adjourn
the meeting from time to time ”).  We note that the authority cited in the response to prior
comment 1 to support the directors ’ ability to adjourn  a meeting is that of the Delaware
Court  of Chancery as opposed to that of a New York court .

3. Please advise  us as to what communication, if any, the Company provided to
shareholders to clarify that notwithstanding that the meeting was “delayed” until
February 25, as disclosed  in the January 28 press release filed as additional definitive
material on January 29, 2020, that the meeting  would still be held on Jan uary 31  in order
for it to be adjourned .

*     *     *

Kai Haakon E. Liekefett, Esq.
Sidley Austin LLP
February 13, 2020
Page 2

 We remind you that the company a nd its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Please contact me at (202) 551 -3444  with any questions.

Sincerely,

/s/ Perry J. Hindin

Perry J. Hindin
Special Counsel
Office of Mergers and Acquisitions