SecProbe.io

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                         American Bio Medica Corporation
                                 122 Smith Road
                           Kinderhook, New York 12106

                                                     June 15, 2005

Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

         Re:      American Bio Medica Corporation
                  Form 10-KSB for Fiscal Year Ended December 31, 2004
                  File No. 000-28666

Dear Sir or Madam:

         On behalf of American Bio Medica Corporation (the "Company"), this
letter serves as the Company's response to the items raised in your letter,
dated June 3, 2005, furnishing the comments of the United States Securities and
Exchange Commission (the "Commission") relating to the Company's Form 10-KSB for
the fiscal year ended December 31, 2004.

         Comment 1:

                  (a) Item 6 of the Company's Form 10-KSB for the year ended
         December 31, 2004 describes critical accounting policies and estimates
         the Company utilizes in the preparation of financial statements in
         accordance with accounting principles generally accepted in the United
         States of America. Significant judgments and estimates used in the
         preparation of the financial statements disclosed in Item 6 included
         estimated reductions to revenue for customer returns and allowances. At
         December 31, 2004 and 2003 the Company disclosed one accrual that
         reduced revenue. This accrual related to estimated customer returns.
         The Company disclosed no other accruals at either date that reduced
         revenue. Though the Company has considered the effect that customer
         programs and incentives could have on revenue, no such programs or
         incentives have ever been adopted by the Company. Disclosure is
         included in Item 6 of the Company's Form 10-KSB regarding customer
         programs and incentives to inform the reader that the impact of such
         programs on revenue are considered, and the effect would be a reduction
         to reported revenue should the Company adopt such programs or
         incentives.

                  The reserve for estimated returns is included in an allowance
         for doubtful accounts and returns of $105,000 at both December 31, 2004
         and 2003. The reserve is netted against accounts receivable. The
         reserve is disclosed on the face of the balance sheet for the fiscal
         years ended December 31, 2004 and 2003. The allowance for doubtful
         accounts was increased from $70,000 to $105,000 during 2003 following
         an increase in sales and accounts receivable.

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United States Securities and Exchange Commission
June 15, 2005
Page 2

                  The Company's results of operations in 2004 were consistent
         with the results from 2003. Accordingly, the Company has adopted
         historical trends as the best indicator of future customer returns.
         Other sensitivity analysis, including the use of actual returns of
         product in subsequent quarters, would most likely yield a similar
         reserve.

                  (b) The Company considers historical return percentages, sales
         for the previous quarter, the relationship of current quarter returns
         to prior quarter sales, and current quarter sales to estimate the
         reserve for customer returns.

                  No external industry data, inventory dating or new product
         considerations are considered in the Company's estimates.

                  (c) Actual bad debts in calendar year 2003 were $29,900 and
         receivables at December 31, 2003 were $1,253,000 net of a reserve for
         $105,000. The percentage of aged receivables greater than 90 days was
         7.29% at fiscal year end 2003 and 6.00% at fiscal year end 2004. Actual
         fourth quarter returns during 2003 were $79,715 compared to gross sales
         in the third quarter of $4,112,166, or 1.94%. Fourth quarter gross
         sales in 2003 were $2,764,433.

                  Actual bad debts in calendar year 2004 were $51,402 and
         receivables at December 31, 2004 were $1,108,000 net of a reserve for
         $105,000. Actual fourth quarter returns during 2004 were $69,836
         compared to gross sales in the third quarter of $3,472,231, or 2.01%.
         Fourth quarter gross sales in 2004 were $2,789,935.

                  The percentage of receivables less than 90 days aged was
         93.51% at December 31, 2004 and 93.87% at December 31, 2003. The days
         sales outstanding also remained consistent at fiscal year end 2004 and
         2003 improving from 45.07 days at December 31, 2003 to 41.77 days at
         December 31, 2004.

                  None of the above-referenced information is based on external
         sources.

                  (d) No shipments were made in connection with customer
         programs or incentives during 2004 or 2003. To the Company's knowledge,
         no shipments were made in excess of any customer's ordinary course of
         business inventory level. The Company has disclosed its revenue
         recognition policy in the section "Significant Accounting Policies" in
         the notes to the financial statements.

                  (e) Please see the attached table providing a roll forward of
         the allowance for doubtful accounts and customer returns. No
         distinction is made between sales made during the current quarter and
         those made in the prior quarter. Neither the allowance nor the returns
         reserve are product or customer specific unless a particular customer
         has been identified that would cause historical data to be inconsistent
         with the necessary reserves. There were not specific products or
         customers identified at December 31, 2004 or 2003.

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United States Securities and Exchange Commission
June 15, 2005
Page 3

                  Returns are netted against sales when returned, impacting the
         quarter during which the returns are received.

                  (f) There was no impact for a change in allowance for doubtful
         accounts and returns in 2004, however the increase in reserve from
         $70,000 to $105,000 resulted in an increase to General and
         Administrative expense and a reduction in Net Income totaling $35,000
         in 2003. The allowance for doubtful accounts was increased from $70,000
         to $105,000 during 2003 following an increase in sales and accounts
         receivable.

                  (g) The allowance for doubtful accounts and returns is
         disclosed on the face of the balance sheet and discussed in Note 2 in
         the footnotes to the financial statements. As the Company believes that
         a similar reserve would result using any reasonable likely assumptions,
         the Company believes that additional disclosure regarding the estimate
         is not necessary. The disclosure on the financial statements along with
         discussion in the footnotes provides investors with a good
         understanding of the dynamics of our sales and revenue, returns and
         allowances and the methods used to estimate those reserves.

         The Company acknowledges that it is responsible for the adequacy and
accuracy of its filings. The Company also acknowledges that 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. The Company acknowledges that it 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.

         Please direct any additional questions or comments to our counsel,
Richard L. Burstein, Esq. at 518-463-3990, who would welcome the opportunity to
discuss any such questions or comments in advance of the preparation of any
written response by the Commission. Thank you.

                         Very truly yours,

                         AMERICAN BIO MEDICA CORPORATION

                         By: /s/ Keith E. Palmer
                             -------------------------------
                             Keith E. Palmer
                             Chief Financial Officer
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                                  ATTACHMENT A

                         American Bio Medica Corporation
         Allowance for Doubtful Accounts and Returns Reserve Rollforward
                           December 31, 2003 and 2004

                                             Reserve For Returns / Allowance For
                                                     Doubtful Accounts
                                                     -----------------

Beginning Balance 12-31-02                           $       70,000.00

Write-offs against allowance                                (19,702.85)

Recoveries                                                   10,476.56

Replenishment of reserve through bad debt                     9,226.29

Provisions
                                                             35,000.00

                                                     -----------------
Ending Balance 12-31-03                              $      105,000.00

Write-offs against allowance                         $      (36,296.63)

Recoveries                                                       95.85

Replenishment of reserve through bad debt                    36,200.78

Provisions                                                          --
                                                     -----------------
                                                     $      105,000.00
                                                     =================

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