December 14, 2009
VIA EDGAR &
UNITED PARCEL DELIVERY

Mr. Brian Cascio
Accounting Branch Chief
Division of Corporation Finance
Mail Stop 3030
Securities and Exchange Commission
Washington, D.C.  20549

Re:  Fonar Corporation
     Form 10-K/A for the fiscal year ended June 30, 2009
     Filed November 10, 2009
     File No. 000-10248

Dear Mr. Cascio:

     I am writing in response to the Commission's  comment letter dated November
24, 2009,  addressed to the attention of Dr. Raymond V. Damadian,  President and
Chief Executive  Officer of Fonar  Corporation.  The responses  contained in our
letter  are  presented  in the same  order  as in the  Commission's  letter.  An
amendment  to our Form  10-K/A for the fiscal  year ended June 30, 2009 is being
filed concurrently herewith.

FORM 10-K/A FOR FISCAL YEAR ENDED JUNE 30, 2009

Note 1:  Description  of Business and Liquidity and Capital  Resources,  page 56
Liquidity and Going Concern, page 56

Comment No. 1.   We reference your response to prior comment 2 which states that
                 since the reductions in workforce were not associated  with any
                 exit or  disposal  activities,  the  requirements  of FASB  ASC
                 420-10-50  and SAB Topic  5.P.4 do not  apply.  We refer you to
                 FASB ASC  420-10-15-3  which provides the scope of the guidance
                 in the exit or disposal cost obligations topic. Since you state
                 on page 49 of your Form 10-K that  during June 2008 you reduced
                 your  workforce,   eliminated   manufacturing   facilities  and
                 restructured  your  diagnostic   imagine   management   service
                 business,  it is not  clear  why you  should  not  include  the
                 required disclosures regarding restructuring activities. Please
                 advise.

Response No. 1.  Note  1 to  the  June 30, 2009  financial  statement  discusses
                 management's  cost-cutting  plan which was initiated during the
                 year  ended June 30, 2009.  The cost-cutting plan  included the
                 following:
                (a) Involuntary conversion of 78 employees;
                (b) Reduction in base pay of substantially all of the employees;
                (c) Consolidation of its management services segment  located in
                    Melville, New York  to the  Company's manufacturing facility
                    also located in Melville, New York;
                (d) Termination of management agreement with Health Diagnostics,
                    LLC.

                There were no one-time termination  benefits  paid to  employees
                who  were  involuntary  terminated.   There  were  no  costs  to
                terminate  the  lease  at the  relocated  facility and  costs to
                relocate   the   employees  to  the manufacturing  facility were
                minimal  as  the two  facilities  are located within 1/2 mile of
                each other.

                The  termination  of  the  management  agreement   with   Health
                Diagnostics, LLC  was  disclosed  in  Note 5  to  the  financial
                statements  and   there  were  no costs   associated  with   the
                termination of the agreement.

                According,  we believe  that the required disclosures of ASC 420
                were met.

Exhibit 31.1

Comment No. 2.   We note that the changes made in the Form 10-K/A in response to
                 prior  comment  10.  We see that you still do not  include  the
                 required reference to internal control over financial reporting
                 in the first  sentence of paragraph 4. Please file an amendment
                 to the Form  10-K/A to  include  certifications  exact  form as
                 prescribed in Item  601(b)(31)(i)  of  Regulation  S-K. You may
                 file an  abbreviated  amendment  that  includes  a cover  page,
                 explanatory note,  signature page and paragraphs 1,2,4 and 5 of
                 the certification.


Response No. 2.  Exhibit 31.1 has been amended to include the required reference
                 to internal control over financial reporting

     Please  feel  free  to  call  me  at (631) 694-2929 in connection with your
comments and our responses.

                                                 Very truly yours,

                                                 /s/ Henry T. Meyer
                                                 Henry T. Meyer
                                                 General Counsel