Lexical characteristics of samples of FORTRAN code, code comments, and English text were compared in order to test the hypothesis that code comments would show characteristics intermediate between FORTRAN code and English text. The code comments were indeed intermediate in the use of special characters and function words but were similar to English text in letter distribution and average word length. X K K 23 Y K K X X 24 W Q Z J J 25 J Z Q Q Q 26 z J J z Z 4.3 Word Length