Dolgenos Newman & Cronin LLP
                         271 Madison Avenue, 12th Floor
                               New York, NY 10016

                                                                   June 7, 2006

BY EDGAR CORRESPONDENCE

Securities and Exchange Commission
Division of Corporation Finance, Mail Stop 6010
Washington, D.C. 20549

         Attention:  Russell Mancuso
                         Branch Chief

                     Re: Avitar, Inc.
                     Registration Statement on Form SB-2/A
                     Filed May 19, 2006 and Amended June 7, 2006
                     File No. 333-134302

Gentlemen:

     On behalf of our client,  Avitar,  Inc.  ("Avitar"  or the  "Company"),  we
attach a letter responding to the comments contained in the letter dated June 6,
2006  (the  "Comment  Letter")  relating  to the  above-referenced  Registration
Statement  on Form  SB-2,  filed on May 19,  2006 and  amended  today,  File No.
333-134302.

     In  addition,  we sent by Fax a marked  copy of  pages in the  Registration
Statement on Form SB-2/A,  filed today,  showing the limited  revisions from the
prior  Registration  Statement on Form SB-2, filed on May 19, 2006. The specific
revisions are (a) the cover page, (b) Item 27, Exhibits and Exhibit Index with a
new Exhibit 10.17 and a revised Exhibit 5.1 and (c) the Signature pages.

     Please call the undersigned at (212) 925-2800 if you have any questions. If
appropriate,  we intend to  furnish an  acceleration  request  from our  client,
Avitar.

                                                              Sincerely,

                                                              /s/

                                                              Eugene M. Cronin

cc: (via fax) Tom Jones, Examiner

                          Dolgenos Newman & Cronin LLP
                         271 Madison Avenue, 12th Floor
                               New York, NY 10016

                                                                    June 7, 2006

BY EDGAR CORRESPONDENCE

Securities and Exchange Commission
Division of Corporation Finance, Mail Stop 6010
Washington, D.C. 20549

         Attention:  Russell Mancuso
                         Branch Chief

                     Re: Avitar, Inc.
                     Registration Statement on Form SB-2/A
                     Filed May 19, 2006 and Amended June 7, 2006
                     File No. 333-134302
                     Letter dated June 6, 2006

Gentlemen:

     On behalf of our client,  Avitar, Inc. ("Avitar" or the "Company"),  we are
responding  to the  comments  contained  in the  letter  dated June 6, 2006 (the
"Comment Letter") relating to the Registration  Statement on Form SB-2, filed on
May 19,  2006  and  amended  today,  File  No.  333-134302,  with a view  toward
facilitating your review of the above-referenced  Registration Statement on Form
SB-2/A.  Our  references in this letter are to the headings and comment  numbers
used in the Comment Letter.


Comment 1.

     In response  to the Comment  Letter,  the  Company  and its  officers  have
confirmed  their  understanding  that,  before  they seek to amend or revise any
terms of the notes or other instruments related to this Registration  Statement,
the Company will first deregister or withdraw the Registration Statement on Form
SB-2/A (File No. 333-134302), as appropriate.

Selling Stockholders
Comment 2.

     The  Company  today  filed  Amendment  No.  2 to  the  Securities  Purchase
Agreement  dated May 4, 2006 as Exhibit 10.17 to the  Registration  Statement on
Form SB-2/A (File No. 333-134302).


Exhibit 5.1
Comment 3.

     The Company  today filed a revised  opinion that refers to the correct Form
SB-2/A as Exhibit 5.1 to the  Registration  Statement  on Form SB-2/A  (File No.
333-134302).

     Please call the undersigned at (212) 925-2800 if you have any questions.

                                            Sincerely,

                                            /s/EUGENE M. CRONIN

                                            Eugene M. Cronin

cc: (via fax) Tom Jones, Examiner