Via Facsimile and U.S. Mail Mail Stop 6010 June 17, 2005 Mr. James L. Herbert President, Chief Executive Officer, Director Neogen Corporation 620 Lesher Place Lansing, Michigan 48912 Re:	Neogen Corporation 	Form 10-K for the fiscal year ended May 31, 2004 	File No. 000-17988 Dear Mr. Herbert: 	We have completed our review of your Form 10-K and have no further comments at this time. 								Sincerely, 								Jim Atkinson 								Branch Chief ?? ?? ?? ?? James L. Herbert Neogen Corporation Page 1