December 17, 2020

Eric Orsic, Esq.
McDermott Will & Emery LLP
444 West Lake Street
Chicago, IL 60606-0029

Re: Enzo Biochem, Inc.
Revised Definitive Proxy Statement on Schedule 14A
Filed December 15, 2020
File No. 1-09974

Dear Mr. Orsic:

We have reviewed the filing above and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand the
disclosure.

Please respond to this letter by amending the filing or by providing the
requested
information. If you do not believe our comments apply to the Company s facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

After reviewing any amendment to the filing and the information you
provide in response
to this comment, we may have additional comments. All defined terms used in
this letter have
the same meaning as in the revised definitive proxy statement unless otherwise
indicated.

Supplement Dated December 15, 2020 to Proxy Statement Dated November 27, 2020

Explanatory Note, page 2

1. Refer to the third paragraph of this section. With a view towards
disclosure, please
provide the basis for the statement that the Notice is deficient
because the Notice was
not timely and Roumell was not a holder of record of the Company s
common stock on
the dates required under the Company s By-Laws. In responding to
this comment,
please specify the aforementioned dates.

2. With a view towards disclosure, please advise us when the Company
conveyed these
deficiencies to Roumell and whether it gave Roumell an opportunity to
correct such
deficiencies.
Eric Orsic, Esq.
McDermott Will & Emery LLP
December 17, 2020
Page 2

Broker Non-Votes, page 3

3. Refer to the disclosure regarding the likelihood that the NYSE will
determine that none
of the proposals may be considered a routine matter on which
brokers have
discretionary authority to vote shares they hold in nominee capacity
without instruction
from the beneficial owners. Reconcile this statement with the subsequent
statement
regarding broker non-votes received. Specifically, if none of the
proposals will be
considered routine such that there will be no broker non-votes, it is
unclear how broker
non-votes could be received. Please advise or revise.

Voting Securities and Votes Required, page 3

4. We note the statement that [b]ecause Roumell did not submit the
Notice to the Company
at least 10 days prior to the filing of the Proxy Statement, the
election of each nominee
for Director (Proposal 1) is an uncontested election within the meaning
of the Company s
By-Laws. With a view towards disclosure, please advise how a
shareholder would
know when to submit such Notice.

* * *

We remind you that the Company is responsible for the accuracy and
adequacy of its
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

Please contact me at (202) 551-3444 with any questions.

Sincerely,

/s/ Perry J. Hindin

Perry J. Hindin
Special Counsel
Office of Mergers
and Acquisitions