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      Blonder Tongue Laboratories, Inc Correspondence

      BLONDER
        TONGUE LABORATORIES, INC.

      One
        Jake Brown Road

      Old
        Bridge, New Jersey 08857

      July
        18,
        2005

      VIA
        EDGAR TRANSMISSION

      Larry
        Spirgel, Assistant Director

      Securities
        and Exchange Commission

      Mail
        Stop
        0407

      Washington,
        DC 20549

                Re:

                Blonder
                  Tongue Laboratories, Inc.

      Form
        10-K for the fiscal year ended December 31, 2004 and

      Form
        10-Q for the quarter ended March 31, 2005

      File
        No. 1-14120

      Dear
        Mr.
        Spirgel:

      This
        letter will serve as a response to each of your comments regarding the
        above-referenced Form 10-K for the fiscal year ended December 31, 2004 and
        Form
        10-Q for the quarter ended March 31, 2005 of Blonder Tongue Laboratories,
        Inc.
        (the “Company”) contained in your letter dated June 7, 2005. Attached to this
        response letter as an addendum is a draft Amendment No. 1 to Form 10-K for
        the
        fiscal year ended December 31, 2004 (“Draft Form 10-K/A”), the form of which the
        Company proposes to file with the SEC following its review and analysis of
        this
        response letter.

      For
        your
        convenience, we have numbered each of our responses to correspond to the
        comment
        of the same number contained in your comment letter dated June 7,
        2005.

      Form
        10-K for the Fiscal Year ended December 31, 2004

      Management’s
        Discussion and Analysis

      1. The
        requested disclosure has been included on pages 17, 18 and 22 of the Draft
        Form
        10-K/A.

      2. The
        requested disclosure has been included on page 18 of the Draft Form 10-K/A.

      Note
        1
        - Summary of Significant Accounting Policies

      3. The
        Company has accounted for its 50% economic interest in Blonder Tongue Telephone,
        LLC (“BTT”) and NetLinc Communications, LLC (“NetLinc”) using the equity method
        due to its lack of substantive participating rights in BTT and NetLinc. For
        example, the Company only owns 49% of the outstanding membership shares of
        BTT
        while the other member

        Larry
          Spirgel, Assistant Director

        July
          18, 2005

        Page
          2

      ("Majority
        Member") owns the remaining 51% of the outstanding memberships shares. While
        the
        Company and the Majority Member share economic rights on an equal
        basis,
        BTT has a Manager that manages, controls, administers and operates the business
        and affairs of BTT, which Manager is appointed by a majority vote of the
        members. Given that the Company only has a 49% voting interest in BTT, it
        cannot
        appoint or remove this Manager, who controls the day to day operations of
        BTT.
        Moreover, this Manager is a controlling member of the Majority Member of
        BTT.
        While certain actions on behalf of BTT require a unanimous vote of members,
        these matters are protective in nature such as creating a new class of
        membership interest, approving a change of control of BTT or a change in
        the
        nature of business of BTT. NetLinc has a similar structure such that the
        Company
        does not have substantive participating rights in the day to day operations,
        but
        merely has protective rights with regard to certain extraordinary corporate
        actions (see details of this structure on page 40 of the Draft Form 10-K/A).
        It
        should also be noted that the Company has a 50% interest in NetLinc and not
        a
        90% interest as referenced in your comment letter. Based on these facts,
        consolidation of BTT and NetLinc is not required pursuant to EITF 96-16 and
        EITF
        04-5. The Company has revised its disclosure on page 40 of the Draft Form
        10-K/A
        to include disclosure of the Company’s and the other parties’ rights in these
        entities.

      4. The
        requested disclosure has been included on page 40 (Note 1(a)) and page 56
        (Note
        13) of the Draft Form 10-K/A.

      5. Given
        that the Company licenses products from Philips and makes payments to Philips,
        there are no revenue recognition issues related to Staff Accounting Bulletin
        104. Nevertheless, the Company has included disclosure on page 46 of the
        Draft
        Form 10-K/A regarding the Company’s accounting policy with regard to royalty and
        license expense.

      General

      6. As
        noted
        in response #3 above, use of the equity method is appropriate. Accordingly,
        the
        Company has included as Exhibit 99.1 to the Draft Form 10-K/A audited financial
        statements of BTT pursuant to Rule 3-09 of Regulation S-X.

      Form
        10-Q for the quarter ended March 31, 2005

      Note
        5
        - Debt, page 8

      7. In
        March,
        2004, the Company’s credit agreement with Commerce Bank was amended to suspend
        the applicability of the cash flow coverage ratio covenant until March 31,
        2005
        and impose a new covenant requiring the Company to achieve certain levels
        of
        consolidated pre-tax income on a quarterly basis commencing with the first
        fiscal quarter ended March 31, 2004. This amendment was made so that the
        Company
        would not be in violation of the cash flow coverage ratio covenant as of
        March
        31, 2004 and eliminated the applicability of such financial covenant for
        all
        periods until March 31, 2005. In March, 2005, this credit agreement was amended
        again to waive the applicability of the consolidated pre-tax income requirement
        as of December 31, 2004, create new consolidated pre-tax income requirements
        for

          Larry
            Spirgel, Assistant Director

          July
            18, 2005

          Page
            3

      each
        quarter starting in March 31, 2005 and suspend the applicability of the cash
        flow coverage ratio until March 31, 2006.

      The
        Company was in compliance with the consolidated pre-tax income covenant for
        the
        fiscal quarters ending March 31, 2004 and September 30, 2004. While the Company
        was not in compliance with this covenant for the fiscal quarters ending June
        30,
        2004, December 31, 2004 and March 31, 2005, the Company received waivers
        of such
        non-compliance each quarter so that the debt was not callable. It should
        be
        noted that this covenant is only measured on a quarterly basis (not annual)
        and
        the amount differs from quarter to quarter and, therefore, a non-compliance
        in
        one quarter does not directly impact the calculation for any subsequent quarter.
        Since this covenant on pre-tax income was measured quarterly, at the time
        of
        each waiver the Company believed it would be in compliance with the covenant
        for
        the next 12 months based on its projections. Accordingly, this treatment
        is in
        compliance with SFAS 78 and EITF 86-30.

      In
        connection with this response to your comments, the Company acknowledges
        that:

              ·

                the
                  Company is responsible for the adequacy and accuracy of the disclosure
                  in
                  its filings;

              ·

                staff
                  comments or changes to disclosure in response to staff comments
                  do not
                  foreclose the SEC 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 SEC or any person under the federal securities
                  laws of
                  the United States.

      Should
        the Staff have any questions, please do not hesitate to contact the
        undersigned.

      Respectively
        submitted,

      /s/
        Eric
        Skolnik

      Eric
        Skolnik,

      Senior
        Vice President - Finance

      and
        Chief
        Financial Officer

      cc: James
        Luksch, Chairman and CEO

    Draft

    July
      18, 2005

    FORM
      10-K/A

      AMENDMENT
        NO. 1

    SECURITIES
      AND EXCHANGE COMMISSION

    WASHINGTON,
      D.C. 20549

              [X]

              ANNUAL
                REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE
                ACT OF
                1934 FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004,
                OR

              [
                ]

              TRANSITION
                REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE
                ACT OF
                1934 FOR THE TRANSITION PERIOD FROM ___________________ to
                __________________

    Commission
      file number: 1-14120

    BLONDER
      TONGUE LABORATORIES, INC.

    (Exact
      name of registrant as specified in its charter)

              Delaware

              52-1611421

              (State
                or other jurisdiction of incorporation or organization)

              (I.R.S.
                Employer Identification No.)

              One
                Jake Brown Road, Old Bridge, New Jersey

              08857

              (Address
                of principal executive offices)

              (Zip
                Code)

    Registrant’s
      telephone number, including area code: (732)
      679-4000

    Securities
      registered pursuant to Section 12(b) of the Act:

              Title
                of each class

              Name
                of Exchange on which registered

              Common
                Stock, Par Value $.001

              American
                Stock Exchange

    Securities
      registered pursuant to Section 12(g) of the Act: None

    Indicate
      by check mark whether the registrant (1) has filed all reports required to
      be
      filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during
      the
      preceding 12 months (or for such shorter period that the registrant was required
      to file such reports), and (2) has been subject to such filing requirements
      for
      the past 90 days. Yes   X
      No

    Indicate
      by check mark if disclosure of delinquent filers pursuant to Item 405 of
      Regulation S-K is not contained herein, and will not be contained, to the best
      of registrant’s knowledge, in definitive proxy or information statements
      incorporated by reference in Part III of this Form 10-K or any amendment to
      this
      Form 10-K. [ X ]

    Indicate
      by check mark whether the registrant is an accelerated filer (as defined by
      Rule
      12b-2 of the Act). Yes
      No

      X

    The
      aggregate market value of voting stock held by non-affiliates of the registrant
      at June 30, 2004: $11,280,369.

    Number
      of
      shares of common stock, par value $.001, outstanding as of March 19, 2005:
      8,002,406.

    Documents
      incorporated by reference:

    Certain
      portions of the registrant’s definitive Proxy Statement for the Annual Meeting
      of Stockholders to be held on May 24, 2005 (which is expected to be filed with
      the Commission not later than 120 days after the end of the registrant’s last
      fiscal year) are incorporated by reference into Part III of this report.

        1

    Forward-Looking
      Statements

      In
        addition to historical information, this Annual Report of Blonder Tongue
        Laboratories, Inc. (“Blonder
        Tongue”
        or the “Company”)
        contains forward-looking statements relating to such matters as anticipated
        financial performance, business prospects, technological developments, new
        products, research and development activities and similar matters. The Private
        Securities Litigation Reform Act of 1995 provides a safe harbor for
        forward-looking statements. In order to comply with the terms of the safe
        harbor, the Company notes that a variety of factors could cause the Company’s
        actual results and experience to differ materially from the anticipated results
        or other expectations expressed in the Company’s forward-looking statements. The
        risks and uncertainties that may affect the operation, performance, development
        and results of the Company’s business include, but are not limited to, those
        matters discussed herein in the sections entitled Item 1 - Business, Item
        3 -
        Legal Proceedings, Item 7 - Management’s Discussion and Analysis of Financial
        Condition and Results of Operations and Risk Factors. The words “believe”,
“expect”, “anticipate”, “project” and similar expressions identify
        forward-looking statements. Readers are cautioned not to place undue reliance
        on
        these forward-looking statements, which reflect management’s analysis only as of
        the date hereof. The Company undertakes no obligation to publicly revise
        these
        forward-looking statements to reflect events or circumstances that arise
        after
        the date hereof. Readers should carefully review the risk factors described
        herein and in other documents the Company files from time to time with the
        Securities and Exchange Commission.

        Explanatory
          Note

            The
              Company is filing this Amendment No. 1 to its Annual Report on Form
              10-K for the
              year ended December 31, 2004 (this “Form
              10-K/A”)
              to include as Exhibit 99.1 certain audited financial information
              required
              under the Securities and Exchange Commission's (“SEC”)
              rules, related to Blonder Tongue Telephone, LLC ("BTT"),
              of which the Company owns a 50% economic interest (“BTT
              Financial Statements”).
              The Company has also expanded or revised certain disclosures in response
              to
              comments received from the SEC after its periodic review of the Company’s Form
              10-K for the fiscal year ended December 31, 2004. These
              changes consist primarily of expanded disclosure in (i) Management’s
              Discussion and Analysis of Financial Condition and Results of
              Operations
              related to the inventory reserve and bad debt expense, and (ii) Notes
              1 and 13
              to the Company’s Financial Statements related to the Company’s interest in BTT,
              NetLinc Communications, LLC and BDR Broadband, LLC, along with the
              Company’s
              accounting policy for royalty and license fees.

            In
              accordance with Rule 12b-15 under the Securities Exchange Act of 1934,
              the
              following Items of the Company’s Form 10-K for the fiscal year ended December
              31, 2004 are being amended in their entirety: Item 7 - Management’s Discussion
              and Analysis of Financial Condition and Results of Operations; Item
              8 -
              Financial Statements and Supplementary Data; and Item 15 - Exhibits
              and
              Financial Statement S