SecProbe.io

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July 7, 2005

United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth St., N.W.
Washington, DC  20549
Attn:    Mr. Jim B. Rosenberg, Sr. Assistant Chief Accountant

Re:      Enzo Biochem, Inc.
         Form 10-K for the FYE 7/31/04, filed 10/14/04
         File no. 001-09974
         Comment Letter dated 6/16/05

Ladies and Gentlemen:

In  response  to your  requests  made in a letter  dated June 16,  2005,  we are
pleased to provide you with the following information:

QUESTION 1A. QUANTIFY CHANGES IN ESTIMATES OF PRIOR PERIOD CONTRACTUAL
ADJUSTMENTS
--------------------------------------------------------------------------------

The  process the  Company  uses to  determine  its  estimate of the  contractual
allowances for its laboratory  services is based upon a rolling monthly weighted
average of  historical  reimbursement  statistics.  The Company  calculates  the
weighted  average of these  statistics  over a twenty  four month  period.  This
statistics  development  process  captures the  aggregate  reimbursements  (cash
applied) for a given month and  compares  that to the  original  gross  invoiced
amounts (the gross  billing is based upon the same standard fee schedule for all
payers) in the aggregate,  by the respective  billable  party  categories  (i.e.
Medicare  and  third  party  payers).   The  Company   calculates   monthly  the
relationship  between the original  aggregate  amounts  billed and the aggregate
reimbursement  amounts and uses this to determine the expected  percentage which
will be collected,  by billable party. The reciprocal percentage of the expected
percentage  is the  estimate of  contractual  allowance  percentage  used by the
Company.

The Company  adjusts for final  settlements on a prospective  basis by adjusting
the contractual  allowance  percentage using the aforementioned  rolling monthly
weighted average  historical  reimbursement  statistics.  The Company's  process
captures  the  actual   aggregate   settlements   on  a  monthly  basis  as  the
reimbursements   are  received  and  applied  to  the  aggregate  open  accounts
receivable;  whereby the above weighted  average is consistently  being adjusted
for the future  period on an on going  basis.  The Company  also  reviews  these
statistics  by billable  party  quarterly  to determine if there are any adverse
trends and for any reimbursement policy changes for any given billable party and
makes the necessary change to the contractual allowance percentage.

During the fiscal years ended July 31, 2004,  2003,  and 2002,  the  contractual
allowance  percentages,  determined  using the rolling monthly  weighted average
historical reimbursement statistics, were 60.9%, 56.7%, and 51.4%, respectively.

<PAGE>

Q1B.  QUANTIFY  THE  REASONABLY  POSSIBLE  EFFECTS  THAT A CHANGE IN ESTIMATE OF
UNSETTLED  AMOUNTS  FROM 3RD PARTY  PAYERS AS OF THE LATEST  BALANCE  SHEET DATE
COULD HAVE ON FINANCIAL POSITION AND OPERATIONS
--------------------------------------------------------------------------------

The Company  projects (by using a sensitivity  analysis)  that each 1% change in
the  contractual  allowance  percentage  could  result  in a  change  in the net
accounts receivable and clinical laboratory services revenue of $340,000,  as of
and for the  fiscal  year ended  July 31,  2004.  The  Company  will  disclose a
sensitivity analysis effect in future MD&A discussions.

Q1C. QUANTIFY PAYER MIX CONCENTRATIONS AND RELATED AGING OF ACCOUNTS RECEIVABLE.
--------------------------------------------------------------------------------

The Company's gross billing for laboratory  services is based upon the Company's
standard fee schedule which is used for all patient payers,  self payers,  third
party payers and Medicare  providers.  The aging of the accounts  receivable  is
maintained  using the gross billed amount and is aged by the invoice  date.  See
Table 1:  Gross  Billing  Payer  Mix  Concentration  and  Table 2 Aging of Gross
Accounts Receivable for fiscal years ending July 31, 2004, 2003, and 2002.

Q1D. AMOUNTS PENDING APPROVAL FROM THIRD PARTY PAYERS
-----------------------------------------------------

The Company views its net accounts receivable as the total amount pending future
approval  from third  party  payers.  See Table 3:  Accounts  Receivable  Net of
Allowances as of July 31, 2004, 2003, 2002. The Company includes in self pay its
self payers plus  amounts that have been denied by third party  payers,  balance
billing  for unpaid  amounts  from  third  party  payers,  and  deductibles  and
co-payments.  The Company does not maintain  historical  percentages for amounts
that get  reclassified  into self  pay.  See Table 4:  Bridging  Gross  Accounts
Receivable to Net for Clinical Lab Operations for the respective fiscal years.

Q2. ALLOWANCE FOR DOUBTFUL ACCOUNTS
-----------------------------------

The Company utilizes a historical  collection  analysis to establish  allowances
for doubtful accounts for each receivable category, which considers the aging of
the receivables and results in an increase in the allowances as the aging of the
related  receivables  increases.  The Company believes collection of receivables
from self payers is subject to credit risk and the patient's ability to pay.

The allowance for doubtful  accounts  also includes the  uncollectible  balances
from third party payers for the insufficient diagnosis information received from
the ordering  physician,  which result in denials of payment.  In addition,  the
allowance is increased when a receivable  from a third party or HMO remains open
due to a denial of coverage based upon the provider  relationships.  The Company
writes off 100% of all accounts  receivable (for all payers) over 300 days as it
assumes all these accounts are  uncollectible.  The written off amounts are kept
on the aging for  internal  purposes.  The  Company  also sets up  reserves  for
accounts under 300 days old. The Company adjusts the estimate for any recoveries
on an ongoing basis through the above historical collection analysis.

                                       2
<PAGE>

Q3 CONTROLS AND PROCEDURES, PAGE 34
-----------------------------------

We will modify the final paragraph of the Controls and Procedures  disclosure in
our future filings, as follows:

Conclusions.  Based upon the Controls and Procedures Evaluation, our CEO and CFO
have each  concluded  that:  1.) our  Disclosure  Controls  and  Procedures  are
effectively  designed to ensure that information required to be disclosed in the
reports the Company  files or submits is  recorded,  processed,  summarized  and
reported,  within the time  periods  specified  in the  Securities  and Exchange
Commission's rules and forms; 2.) our Disclosure  Controls and Procedures ensure
that  information  required to be disclosed is accumulated  and  communicated to
management, including the CEO and CFO, as appropriate, to allow timely decisions
regarding  required  disclosure;  and 3.) our Internal Controls are effective to
provide reasonable  assurance that our financial statements are fairly presented
in conformity with generally accepted accounting principles.

Q4 POLICY FOR DETERMINING WHEN AN ALLOWANCE IS RECOGNIZED FOR A RECEIVABLE OR
WHEN ONE IS WRITTEN OFF
--------------------------------------------------------------------------------

The  allowance  for  doubtful  accounts  is  estimated  based on our  historical
collection  experience using a retrospective  collection analysis,  and accounts
receivable  aging  models  based on  thresholds  for age.  The Company  utilizes
historical  uncollectible  amounts by payer mix and uses this data to  determine
the allowance for doubtful  accounts by respective payer mix. The Company writes
off 100% of all accounts receivable (for all payers) over 300 days as it assumes
all these  accounts are  uncollectible.  The written off amounts are kept on the
aging for internal  purposes.  The Company also provides for accounts  under 300
days old.

Q5 - REVENUE RECOGNITION, PAGE F-8
----------------------------------

The Company has certain non exclusive supply agreements with distributors. These
distributors  report their  shipments of products to their  customers  and their
corresponding manufacturing and processing costs for these shipped products. The
Company   records  the  revenue  from  these  supply   agreements   net  of  the
distributors' manufacturing and processing costs.

During the fiscal years ended July 31, 2004,  2003, and 2002, the  manufacturing
and processing cost of these products sold was $7.4 million,  $7.0 million,  and
$6.5 million, respectively.

With respect to EITF 01-9, issues 3-6:

Issue 3--Under what circumstances  should up-front  nonrefundable  consideration
given by a vendor to a customer be  recognized  as an asset of the vendor rather
than an immediate charge in the vendor's income statement?

We  have  never  paid  up-front  nonrefundable   consideration  to  any  of  our
distributors or their customers.

                                       3
<PAGE>

Issue 4--If a vendor offers a sales incentive  voluntarily and without charge to
customers  that is  exercisable  by a customer as a result of a single  exchange
transaction,  when should the vendor recognize and how should the vendor measure
the cost of the sales incentive if it will not result in a loss on the sale of a
product or service?

We do not offer sales incentives.

Issue  5--For the sales  incentive  described in Issue 4, when should the vendor
recognize and how should the vendor  measure the cost of the sales  incentive if
it will result in a loss on the sale of a product or service?

Not applicable.

Issue 6--If a vendor offers a customer a rebate or refund of a specified  amount
of cash  consideration  that is  redeemable  only if the  customer  completes  a
specified  cumulative level of revenue  transactions or remains a customer for a
specified  time  period,  when  should the vendor  recognize  and how should the
vendor measure the cost of the offer?

We don't offer rebates or refunds for any reason.

Q6 NOTE 7 - LITIGATION, PAGES F-13 TO F-15
-------------------------------------------

The second  paragraph of the note  describes a shareholder  complaint  alleging,
among other things,  securities  fraud,  and is entitled Glaser et al. vs. Gross
and officers and directors of Enzo.

As required by Reg 229.103 of Reg S-K, the information  provided  includes:  the
name of the  court in which  proceedings  are  pending,  date  proceedings  were
instituted, the principal parties to the proceedings, a description of the facts
underlying the proceedings,  and the relief sought, which is in excess of 10% of
our consolidated current assets.

The company believes it has complied with SFAS 5, paragraphs 8-10,  because,  in
the opinion of management, it is not probable that a liability has been incurred
and  therefore no accrual has been made for a loss  contingency.  It is also the
opinion of management  that there is a less than reasonable  possibility  that a
loss has been incurred and therefore,  no estimate of the possible loss or range
of loss has been given.

The sixth  paragraph  of the note  describes a complaint  made by Roche  against
Enzo.  The  information  provided  includes:  the  name of the  court  in  which
proceedings are pending, date proceedings were instituted, the principal parties
to the proceedings,  a description of the facts underlying the proceedings,  and
the relief sought.

It is the opinion of  management  that it is not probable  that a liability  has
been incurred and therefore no accrual has been made for a loss contingency.  It
is  also  the  opinion  of  management  that  there  is a less  than  reasonable
possibility  that a loss has been  incurred  and  therefore,  no estimate of the
possible loss or range of loss has been given.

                                       4
<PAGE>

The status of these  complaints  was updated in Part II, Item 1 of our April 30,
2005 10-Q filing  made on June 9, 2005.  Developments  described  in that filing
strengthen management's opinion that there is a less than reasonable possibility
that any losses have been incurred.

In connection to our response to your comments, we acknowledge that:

     o    The Company is responsible for the adequacy and accuracy of the
          disclosures in the Form 10-K.

     o    Staff comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any action with respect to
          the 10-K filing.

     o    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.

Very truly yours,

/s/ Barry W. Weiner
President, Chief Financial Officer and Director

                                       5
<PAGE>

Enzo Biochem                                               TABLE 1
Gross Billing Payer Mix Concentration

<TABLE>
<CAPTION>
CATEGORY                       7/31/2004                        7/31/2003                          7/31/2002
--------------------------------------------------------------------------------------------------------------------------
<S>                            <C>              <C>             <C>               <C>              <C>                <C>
MEDICARE                       31,231,104       32%             29,495,752        32%              26,825,154         28%
THIRD PARTY PAYERS             38,075,053       39%             35,218,146        38%              36,426,400         38%
PATIENT-SELF PAY               10,766,915       11%             10,385,728        11%              10,885,916         11%
HMO'S                          18,625,752       19%             17,113,657        19%              22,617,119         23%
                   --------------------------------------------------------------------------------------------------------
TOTAL                          98,698,824      100%             92,213,283       100%              96,754,589        100%
                   ========================================================================================================

</TABLE>

<PAGE>

<TABLE>
<CAPTION>

TABLE 2             ENZO CLINICAL LABS, INC
                    AGING OF GROSS ACCOUNTS RECEIVABLE AS OF 07/31/2004
                    ------------------------------------------------------------------------------------------------------------
<S>                         <C>          <C>             <C>          <C>             <C>              <C>               <C>
                                                 31             61           91
                                                 to             to           to     Greater than
                                   30            60             90          120              120       Grand total       As %
CATEGORY           ------------------------------------------------------------------------------------------------------------
--------
MEDICARE                    4,485,639     3,282,602      1,279,771      936,898        5,638,539       15,623,449          31%
THIRD PARTY PAYERS          5,692,879     3,608,284        591,901      430,836          223,416       10,547,316          21%
PATIENT-SELF PAY            2,320,132       988,526        609,957      442,580        6,513,234       10,874,429          22%
HMO'S                       2,167,120     2,196,744        849,797    1,655,237        5,857,900       12,726,798          26%
                   -------------------------------------------------------------------------------------------------------------
TOTAL                      14,665,770    10,076,156      3,331,426    3,465,551       18,23