Mail Stop 7010

                                                November 17, 2005



Mr. Anthony J. Simonetta
Strategic Diagnostics Inc.
111 Pencader Drive
Newark, Deleware 19702

	RE:	Strategic Diagnostics Inc.
      Form 10-K for the year ended December 31, 2004
      Filed March 30, 2005
      File No. 000-22400


Dear Mr. Simonetta:

      We have reviewed your response letter dated November 15,
2005
and have the following additional comments.  After reviewing this
information, we may or may not raise additional comments.

FORM 10-K FOR THE PERIOD ENDED DECEMBER 31, 2004
1. We note that you anticipate recording the costs to produce a
custom
antibody as inventory at the lower of cost or market.  Please tell
us
what you define as market and specifically how and when you plan
to
assess the custom antibody costs for impairment.
2. We understand from your previous response letters that
customers
can request additional antibodies using the same animals from
their
initial order.  Please tell us what consideration you have given
to
this situation as it relates to your proposed accounting for the
custom antibody costs.  In particular, address the following.
* Tell us how the timing of a customer request for additional
antibodies affects your proposed policy.  Address how and when a
customer makes such requests.  If the request is made prior to the
delivery of the initial order, address how you will allocate costs
between the initial order and subsequent orders.  If the request
is
made subsequent to the delivery of the initial order, tell us how
you
will reflect appropriate gross margins on the subsequent antibody
deliveries as we assume that, in accordance with your proposed
accounting for the costs to produce a custom antibody, all such
costs
would have been expensed upon shipment of the original order.  In
addition, if you are recognizing fees from housing an animal and
waiting on a decision from a customer regarding subsequent
antibody
orders, tell us how you will treat the accumulated costs related
to
the initial antibody production.
* Please ensure that your response contemplates your business
practices utilized in each period presented in your fiscal 2004
Form
10-K through the current period.

3. Tell us the typical timeframe between the completion of your
work
to produce the custom antibodies and shipment to your customers.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comments
and
provides any requested supplemental information.  Detailed
response
letters greatly facilitate our review.  Please file your response
letter on EDGAR.  Please understand that we may have additional
comments after reviewing your response to our comments.

     If you have any questions regarding these comments, please
direct
them to Patricia Armelin, Staff Accountant, at (202) 551-3747,
Jeanne
Baker at (202) 551-3691 or, in their absence, to the undersigned
at
(202) 551-3768.


            Sincerely,



                  John Cash
                  Accounting Branch Chief


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Mr. Anthony J. Simonetta
Strategic Diagnostics Inc.
November 17, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE