SecProbe.io

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April 19, 2005

Mail Stop 0306

Andrew H. Meyers
Chief Financial Officer
Langer, Inc.
450 Commack Road
Dear Park, NY 11729-4510

Re:	Langer, Inc.
      Amendment No. 4 to Registration Statement on Form S-1
	Filed April 14, 2005
      File No. 333-120718

Dear Mr. Meyers:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  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 some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form S-1

Financial Statements

Note 6.  Long-Term Debt - Page F-20
1. Refer to our prior comment 9.  We see you indicate you account
for
the protection payment and the impact of the protection payment on
the $3 Million Note as embedded derivative instruments under
Statement 133.  Please supplementally provide us with the specific
paragraphs therein (or provide us with references to other
authoritative generally accepted accounting principles) that
support
accounting for these contractual terms as derivatives.  Tell us
(quantify) how your financial statements would change if the
"embedded derivatives" were accounted for as contingencies under
Statement 5 rather than derivatives.  Finally, revise this note to
clarify, if true, that what you are accounting for is (a) the
"protection payment", which relates to the $7.5 Million Note and
(b)
the impact on the $3 Million Note of the protection payment as
well
as the timing of any repayment on the notes.  Also, revise the
filing
to better describe your accounting for both the Notes and the
protection payment.  We may have further comments after reviewing
your response and revisions.

*  *  *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      You may contact Thomas Dyer at (202) 824-5564 or Daniel
Gordon
at (202) 942-2813 if you have questions regarding comments on the
financial statements and related matters. Please contact Adelaja
Heyliger at (202) 824-5082 or me at (202) 942-1880 with any other
questions.

Sincerely,

							Peggy A. Fisher
      Assistant Director

cc (via fax):	Robert L. Lawrence, Esq., Kane Kessler P.C.
212.245.3009
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Langer, Inc.
April 19, 2005
Page 1

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