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Mail Stop 6010



July 22, 2005

Andrew Makrides
President, Chief Executive Officer
Bovie Medical Corporation
734 Walt Whitman Road
Melville, New York 11747


Re:	Bovie Medical Corporation
	Amendment No. 3 to Registration Statement on Form S-3
	Filed July 15, 2005
	And Documents Incorporated by Reference
	File No. 333-120741

Dear Mr. Makrides:

      We have reviewed your revised filings and have the following
comments.  Where indicated, we think you should revise your
documents
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Amendment No. 3 to Registration Statement on Form S-3

Risk Factors, page 6

1. We note your response to comment 1.  Please demonstrate that
deleted disclosure was not material, considering both quantitative
and qualitative factors.  If you do not know the identity of your
ultimate customers, it is unclear why investors should not know of
the risks created by that lack of knowledge.

Where You Can Find More Information, page 29

2. You should incorporate all required reports during the
applicable
period, not just the latest amendments to those reports.

Exhibit 5.1

3. Tell us the reasons for the changes from the version of the
opinion that you filed with the previous amendment.

4. Counsel must also revise its opinion to specifically consent to
the filing of the opinion as an exhibit to the registration
statement.

Amendment No. 1 to Annual Report on Form 10-KSB for the year ended
December 31, 2004

Item 6 - Management`s Discussion and Analysis

Results of Operations

5. We note the revisions you have made in response to comment 19
in
our letter dated May 12, 2005.  Please continue your efforts to
further explain the reasons for the material variations in your
operating results during the periods discussed.  For example, we
note
you have indicated that your sales to Arthrex increased by $2.4
million for fiscal 2004 as compared to fiscal 2003 but you have
not
fully indicated the reasons why your sales to Arthrex increased by
this amount.

Item 8A - Disclosure Controls and Procedures

6. We note that the scope of your conclusion as to the
effectiveness
of your disclosure controls and procedures is still limited by
your
statement that your disclosure controls and procedures are
effective
"to bring to the attention of the Company`s management the
relevant
information necessary to permit an assessment of the need to
disclose
material developments and risks pertaining to the Company`s
business
in its periodic filings with the Securities and Exchange
Commission."
Since the conclusion as to the effectiveness of the disclosure
controls and procedures only addresses a subset of the elements of
the term "disclosure controls and procedures" as set forth in
Exchange Act Rule 13a-15(e), please either expand your conclusion
to
address all of the material elements of that term or,
alternatively,
to the extent that the conclusion would be true, please remove the
limitation on the scope of the conclusion (for example, by
removing
all of the words that appear after the word "effective").

Item 10 - Executive Compensation

7. We note the employment agreements that you have filed as
exhibits
to your Form 10-KSB/A and your disclosure that "[i]n January 3,
2004,
we extended employment contracts with certain of its officers for
two
years."  Please tell us whether any written amendments to the
employment agreements you have filed have been entered into.  If
written amendments do exist, they should also be filed as
exhibits.

8. We note the first footnote to the table on page 22 that
summarizes
the basic terms of the employment agreements.  Please tell us how
you
determined to include total extensions for six years for purposes
of
indicating the expiration dates of the related employment
agreements.
Also, it appears that the employment agreements identified in the
table may be terminated by the employee at any time upon at least
thirty (30) days prior written notice to your company.  As
applicable, please disclose the terms upon which the employees may
terminate the employment agreements identified in the table.

9. We note the provisions contained in Sections 10(d) of the
agreements with each of Messrs. Makrides, Saron and Citronowicz
and
Section 10 (c) of the agreement with Mr. Peabody.  Please revise
your
disclosure to describe the termination and change-in-control
arrangements as required by Item 402(g)(2) of Regulation S-B.

Exhibits

10. Your response to comment 8 indicates that that the Emergency
Medical Innovations agreement may be material; therefore, it
should
be filed.

* * *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Traci Hornfeck at (202) 551-3642, or Brian
Cascio, Branch Chief, at (202) 551-3676, if you have questions
regarding comments on the financial statements and related
matters.
Please contact Tim Buchmiller at (202) 551-3635 or me at (202)
551-
3617 with any other questions.
							Sincerely,



							Russell Mancuso
							Branch Chief

cc:	Alfred V. Greco, Esq. (via fax)
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Andrew Makrides
Bovie Medical Corporation
July 22, 2005
Page 4




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