SecProbe.io

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June 30, 2005

By Facsimile ((212) 308-0132) and U.S. Mail

Guy P. Lander, Esq.
Davies Ward Phillips & Vineberg LLP
625 Madison Avenue, 12th Floor
New York, NY  10022

	Re:	Pure World, Inc.
		Schedules 14D-9 filed June 6 and 17, 2005
		File No. 005-33973

Dear Mr. Lander:

      We have reviewed your 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.

Schedules 14D-9 filed June 6, 2005
1. We note the statement that Pure World disclaims any obligation
to
update or revise the information contained in any "forward-looking
statements."  This disclaimer is inconsistent with the
requirements
of General Instruction F of Schedule 14D-9 and your obligations
under
Rule 14d-6(c) to amend the Schedule to reflect a material change
in
the information previously disclosed.  Please confirm that the
company will avoid using this statement in all future tender offer
materials.
2. The filing bears an incorrect EDGAR header identification tag.
This preliminary communication should have been filed under cover
of
Schedule 14D-9-C.  Please fax a request for this header
identification tag to be corrected to the attention of Sylvia
Pilkerton in the Office of Edgar and Information Analysis at (202)
772-9216.

Schedule 14D-9 filed June 17, 2005

The Solicitation or Recommendation - Background of the Offer, page
6
3. Please provide us a supplemental copy of any written materials
presented by Adams Harkness to your board, including any presented
on
June 3, 2005.
4. In the first full paragraph on page 7, you state that the
company
publicly announced on June 3, 2004 that it had discontinued its
efforts to explore strategic alternatives. In the next paragraph,
you
disclose that in January 2005, the board directed Adams Harkness
to
renew its efforts to find an acquirer for the company. Please
explain
what changed between June 2004 and January 2005 to explain the
board`s change of heart.
5. Refer again to the second full paragraph on page 7. Describe
the
material terms of the three offers received by the company,
including
the per share value or range of values represented by each. Also,
explain what you mean by the statement that Naturex displayed the
"strongest interest." Does this mean Naturex` offer was the
highest?
6. On page 7, fourth paragraph, explain what happened to the three
other potential bidders referenced.
7. We note that the offer received from Stauber in May 2005 was at
a
significantly higher per share value than Naturex` current bid.
In
light of this fact, please expand to explain why the board chose
the
Naturex bid as the superior proposal. For example, explain the
statement in the first paragraph on page 11 that the company had
not
received a final bid from Whitney? Why was this determinative,
since
Whitney`s affiliate`s bid was already higher than Naturex`? We
note
your reference to "the status of negotiations with Naturex" and
its
"timely offer," but these matters do not seem so significant as to
preclude pursuit of a higher offer.

The Solicitation or Recommendation - Factors for the
Recommendation,
page 12
8. You have listed various factors that the board considered in
recommending this offer. However, simply listing the factors,
without
explaining how the board analyzed them, is of limited usefulness
to
shareholders. For example, how did the economic climate factor
into
the board`s decision? Provide similar clarification for the other
listed factors.
9. Please describe briefly the registrant`s "prospects if it were
to
remain independent."

Additional Information, page 16
10. We note in Annex A (page A-11) that it appears Mr. Koether
will
receive, in addition to payments for his Pure World securities, a
change of control payment under his employment agreement of
$645,000.
Please tell us what consideration you have given to including this
information (and similar information for any other of your
directors
or executive officers) in this section. It should also be
referenced
in the discussion of potential conflicts of interest on page 13.

Annex A
11. We note that you provided the information required by Rule
14f-1
as an annex to the Schedule 14D-9 but did not file it separately
on
Edgar.  Please tell us what consideration you gave to filing the
document on Edgar using the header tag "SC14F1."  Refer to the
Edgar
Filer Manual, which is available on our website at www.sec.gov.

Closing Information

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      Please direct any questions to me at (202) 551-3619 or, in
my
absence, to Christina Chalk, Special Counsel, at (202) 551-3263.
You
may also contact me via facsimile at (202) 772-9203.  Please send
all
correspondence to us at the following ZIP code: 20549-3628.

					Sincerely,

					Daniel F. Duchovny
					Attorney-Advisor
					Office of Mergers & Acquisitions

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Guy P. Lander, Esq.
Davies Ward Phillips & Vineberg LLP
June 30, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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