Seligman Portfolios, Inc.

                                           May 1, 2006

VIA EDGAR

Securities and Exchange Commission
100 F Street, NE
Washington, DC  20549

Attention: Keith O'Connell

Re:   Seligman Portfolios, Inc.
      Post-Effective Amendment No. 36
      SEC File Numbers:  33-15253 and 811-5221

Dear Mr. O'Connell:

Reference is hereby made to  Post-Effective  Amendment No. 36 filed on April 24,
2006 (the  "Amendment") to the  Registration  Statement of Seligman  Portfolios,
Inc.  (the "Fund") on Form N-1A.  The  Amendment has been marked to show changes
from the filing on February 28, 2006.  The Amendment was filed  pursuant to Rule
485(b) for effectiveness on May 1, 2006.

We have revised the Fund's Registration  Statement to include previously omitted
information  and  non-material  updates  and to address a comment  raised by you
relating  to  one  other  mutual  fund  (managed  by  J.  & W.  Seligman  &  Co.
Incorporated)  that has similar  objectives  and  strategies as Seligman  Common
Stock  Portfolio  (the  "Portfolio"),  a  portfolio  of the  Fund.  For  ease of
reference,  your comment (along with the applicable response) is repeated below.
Such comment relates to disclosure contained in the Fund's Prospectus.


1.    Under the caption "Principal Investment  Strategies",  with respect to how
      common  stocks are  chosen for the  Portfolio,  revise the  disclosure  to
      distinguish between "Security Evaluation" and "Fundamental Analysis".

      Response:  The  disclosure  has been  revised to clarify that the security
      evaluation process includes fundamental research.



                          ----------------------------

We believe that the  foregoing  addresses  your comment.  In addition,  the Fund
hereby represents as follows:

            i.    The Fund is  responsible  for the adequacy and accuracy of the
                  disclosure in the filing submitted herewith.

            ii.   Staff  comments or changes to  disclosure in response to Staff
                  comments in the filings reviewed by the Staff do not foreclose
                  the Securities and Exchange Commission (the "Commission") from
                  taking any action with respect to the filing.

            iii.  The Fund may not  assert  Staff  comments  as a  defense  in a
                  proceeding initiated by the Commission or any person under the
                  federal securities law.

If you have any questions related to this filing, please call the undersigned at
(212) 850-1703.


                                      Very truly yours,

                                      /s/ Joseph D'Alessandro

                                      By: Joseph D'Alessandro
                                          J. & W. Seligman & Co. Incorporated
                                          Law & Regulation