Mail Stop 0308
							June 6, 2005


Mr. David Freeman
President and Chief Executive Officer
Lydall, Inc.
One Colonial Road
Manchester, Connecticut 06040

		RE:	Lydall, Inc.
			Form 10-K for Fiscal Year Ended December 31, 2004
			Filed March 16, 2005
			File No. 1-07665

Dear Mr. Freeman:

	We have reviewed the responses in your letter dated May 20,
2005
and have the following additional comment.  Please be as detailed
as
necessary in your explanation so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	We welcome any questions you may have about our comment or on
any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.

Form 10-K for Fiscal Year Ended December 31, 2004

Notes to Financial Statements

Note 1. Significant Accounting Policies, page F-7

Revenue Recognition, page F-8

1. Based on our review of your response to comment 10 from our
letter
dated April 21, 2005, we understand that your customers have a
right
to return the products that they purchase from you; yet you do not
record an estimate of returns at the time of recording the sale
because you believe such returns to be immaterial.   Based on the
information you have provided with respect to sales returns and
allowances in fiscal 2004, we are unclear as to why you believe
your
sales returns are immaterial.  In particular, while we acknowledge
that the returns are immaterial relative to total sales, it does
not
appear that gross margin on the returns is immaterial relative to
operating income and/or income before taxes.  Thus, please refer
to
SFAS 48 and tell us why you continue to believe that you are not
required to record an estimate of sales returns at the point of
sales
recognition.  Or, if after reassessing your accounting you now
believe that your accounting should be revised, please show us how
you plan to revise your financial statements accordingly.  Please
also confirm that you will disclose Schedule II information with
respect to your sales returns and allowances.

	As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a response letter that keys your response to our
comment and provides any requested 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 responses to our comments.

	You may contact Adam Phippen, Staff Accountant, at (202) 551-
3336 or, in his absence, Robyn Manuel at (202) 551-3823 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3843 with any other
questions.

								Sincerely,



								George F. Ohsiek, Jr.
								Branch Chief

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Mr. David Freeman
Lydall, Inc.
June 6, 2005
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