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Mail Stop 4561          February 20, 2008  Denis A. Krusos Chief Executive Officer CopyTele, Inc. 900 Walt Whitman Road Melville, NY 11747
Re: CopyTele, Inc.
Form 10-K for Fiscal Year Ended October 31, 2007
 Filed January  15, 2008
 File No. 000-11254

Dear Mr. Krusos:

We have reviewed the above referenced filing and have the following comment.
Please note that we have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your document.
If indicated, we think you s hould revise your document in re sponse to this comment.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In our
comment, we may ask you to provide us with  supplemental information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.

Please understand that the purpose of our re view 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 comment or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Denis A. Krusos
CopyTele, Inc.
February 20, 2008 Page 2  Form 10-K for Fiscal Year Ended October 31, 2007

 Item 8. Financial Statements and Supplementary Data

 Note 4.  Investment in and Related Party Transactions with Digital Info

Security Co., Inc., page F-15
1. We note your disclosure that your investment  in DISC is recorded at cost.  Please
tell us how you considered paragraph 3( a) of SFAS 115 with respect to this
investment.

* * * * * * *

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please submit all correspondence and supplemental materials
on EDGAR as required by Rule 101 of Regulat ion S-T.  If you amend your filing, you
may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comment and provides any
requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comm ents after reviewing any amendment and
your response to our comment.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comment, please provide, in writing, a
statement from the company acknowledging that:

• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• 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
• 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.

Mr. Denis A. Krusos
CopyTele, Inc. February 20, 2008 Page 3
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
 You may contact Mark Sh annon, Staff Accountant, at  (202) 551-3299 or me at
(202) 551-3451 if you have any questions  regarding the above comment.
        S i n c e r e l y ,                  Mark Kronforst
Accounting Branch Chief