SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 03-09

February 24, 2005

Mr. Marc D. Grodman
Chief Executive Officer
Bio-Reference Laboratories, Inc.
481 Edward H. Ross Drive
Elmwood Park, NJ 07407

Re:	Bio-Reference Laboratories, Inc.
	Form 10-K for the fiscal year ended October 31, 2004
	File No. 000-15266

Dear Mr. Grodman:

We have reviewed your filings and have the following comments.  We
have limited our review of the above referenced filings to only
those
issues addressed.  We think you should revise your documents in
response to these comments in future filings beginning with your
Form
10-K for the fiscal year ended October 31, 2005.  In a
supplemental
letter, please either confirm that you will comply with these
comments in future filings or, if you disagree, we will consider
your
explanation as to why our comments are inapplicable or a revision
is
unnecessary.  Please provide us this letter with detailed
explanations keyed to our comments within 10 business days of the
date of this letter or tell us when you will provide the letter
prior
to the expiration of the 10-day period.  Please file your letter
on
EDGAR under the form type label CORRESP.  Please understand that
we
may have additional comments after reviewing your letter.

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 10-K for the fiscal year ended October 31, 2004

Business

Billing, page 6

1. Please consider expanding your disclosures regarding "Billing"
to
include the following:

a. State if your billing system generates contractual adjustments
based on fee schedules for the patient`s insurance plan for each
patient encounter or if an estimate of contractual allowances is
made.  If an estimate is made, state what factors are considered
in
determining the estimate.
b. Disclose your policy for collecting co-payments, if applicable.

Management`s Discussion and Analysis

Overview, Page 17

2. Please consider expanding your disclosures to include the
following:

a. For each period presented, quantify and disclose the amount of
changes in estimates of prior period contractual adjustments that
you
recorded during the current period. For example for 2004, this
amount
would represent the amount of the difference between estimates of
contractual adjustments for services provided in 2003 and the
amount
of the new estimate or settlement amount that was recorded during
2004.
b. Quantify and disclose the reasonably possible effects that a
change in estimate of unsettled amounts from 3rd party payors as
of
the latest balance sheet date could have on financial position and
operations.
c. Disclose in a comparative tabular format, the payor mix
concentrations and related aging of accounts receivable.  The
aging
schedule may be based on management`s own reporting criteria (i.e.
unbilled, less than 30 days, 30 to 60 days etc.) or some other
reasonable presentation.  At a minimum, the disclosure should
indicate the past due amounts and a breakdown by payor
classification
(i.e. Medicare, Medicaid, Managed care and other, and Self-pay).
We
would expect Self-pay to be separately classified from any other
grouping.  If your billing system does not have the capacity to
provide an aging schedule of your receivables, disclose that fact
and
clarify how this affects your ability to estimate your allowance
for
bad debts.
d. If you have amounts that are pending approval from third party
payors (i.e. Medicaid Pending), please disclose the balances of
such
amounts, where they have been classified in your aging buckets,
and
what payor classification they have been grouped with.  If amounts
are classified outside of self-pay, tell us why this
classification
is appropriate, and disclose the historical percentage of amounts
that get reclassified into self-pay.

3. Please revise the filing to discuss your critical accounting
policies.  See Financial reporting release FR-60.

Liquidity and Capital Resources, page 20

4. State the steps you take in collecting accounts receivable.
Disclose your policy with respect to determining when a receivable
is
recorded as a bad debt and when a write off is recorded.  Clarify
the
threshold (amount and age) for account balance write-offs.

5. Disclose the day`s sales outstanding for each period presented.
Disclose the reasons for significant changes from the prior
period.

Financial Statements

Contractual Credits and Provision for Doubtful Accounts, page 49

6. State if you use specific identification for account write-offs
of
accounts receivable.

*    *    *    *

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.  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.

In connection with responding to our comments, 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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

You may contact Whitnie Storey, Staff Accountant, at (202) 824-
5385
or Mary Mast, Senior Accountant, at (202) 942-1858 if you have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 942-1803.

								Sincerely,

								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
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Mr. Marc D. Grodman
Bio-Reference Laboratories, Inc.
Page 3

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