February 17, 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. 2 to Registration Statement on Form S-1
	Filed February 11, 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

Prospectus Summary - Page 1
1. We note your response to prior comment 1 and the additional
disclosure on page 5.  Please update to disclose whether the put
option has been exercised and the resulting effects of the
exercise.
We may have further comment.
2. Additionally when the revised S-1 is filed, please ensure that
corresponding updates are made throughout the prospectus to
reflect
financial results for the year ended December 31, 2004.  We note,
for
example, that your Dilution disclosure on page 29 is as of
September
30, 2004.
Risk Factors - Page 9

We may be adversely affected by legal actions or proceedings.... -
Page 11
3. We note your response to prior comment 16 and your additional
disclosure on pages 51 and F-43.  Please disclose under this risk
factor that the obligation to Silipos under the purchase agreement
can be as high as $4.5 million.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations -
Page 37

Results of Operations - Page 41
4. We have read and reviewed your response to prior comment 6 and
the
related changes made to the document.  Please revise the document
to
provide similar detailed disclosures for each significant variance
for all periods presented.
5. Refer to our prior comment 15.  We are still evaluating your
response to our comment and may have additional comments after
completing our review.

Business - Page 57

Patents and Trademarks - Page 63
6. We note your response to prior comment 8 and the revised
disclosure on page 63.  Please quantify the percentage of your
revenues attributable to the AEI license in each period for which
financial statements are presented.

Management - Page 71

Executive Compensation - Page 74
7. Please explain why you are unable to determine Andrew Meyers`
bonus for the year ended December 31, 2003.

Principal Stockholders - Page 79
8. Given your response to prior comment 10 and your added
disclosure
in footnote 6 to the Beneficial Ownership table, please explain
why
you continue to state that Atlas Capital beneficially owns 7.0% of
your common stock.  Please disclose any rights Atlas Capital has
to
the stock it holds as nominee for the mentioned "various persons."
Please also tell us whether there are any affiliations among these
persons.

*  *  *
      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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      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.
February 17, 2005
Page 1