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     Correspondence

June 24, 2005

Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington D.C. 20548

Re:   Meridian Bioscience, Inc.

         Form 10-K for the fiscal year ended September 30, 2004

         File No. 000-14902

I am in receipt of the SEC’s
comments following your review of our response, dated May 26, 2005, to your comment letter
dated May 10, 2005 on Meridian’s Form 10-K for the fiscal year ended September 30,
2004. Meridian has responded to each of the points below.

Comment No.1-Revenue
Recognition (Rebates)

SEC Staff Comment

Please propose disclosures about the
nature and amount of your rebate provision and the effect that could result from using
other reasonably likely assumptions than those used in calculating the rebate provision.
In addition, please provide a three year roll forward of the rebate provision that
separately quantifies the increases and decreases to the provision related to sales made
in the current year from increases and decreases related to sales made in prior years. If
increases or decreases related to prior years sales has ever been material, please further
justify why disclosing the roll forward and the effect of changes in the rebate provision
or revenue would not be applicable.

Meridian’s Response

The disclosure in Note 1(h) to the
consolidated financial statements reads as follows:

“Revenue for the US Diagnostics
operating segment is reduced at the date of sale for estimated rebates and cash discounts
that will be claimed by customers. Management estimates reserves for rebate agreements and
cash discounts based on historical statistics, current trends and other factors. Changes
to the reserves are recorded in the period they become known.” This language also
appears in ITEM 7. Management’s Discussion and Analysis of Financial Condition and
Results of Operations under Critical Accounting Policies.

As noted in our May 26, 2005 response
to the SEC’s comment letter dated May 10, 2005, “The rebate accrual and cash
discount reserve were $1,318,000 and $10,000, respectively at September 30, 2004.” It
further states, “The cash discounts will be removed from the critical accounting
policy disclosure in future filings.” In future filings, we will disclose the amount
of the rebate accrual in addition to the disclosures above regarding the nature of the
rebate accrual.

A further explanation of the rebates
will address your comment regarding the effect that could result from using other
reasonably likely assumptions than those used in calculating the rebate provision and any
adjustments to the provision related to sales made in prior years.

Each month, distributors report
rebates for sales they made to end customers (e.g. hospitals) during the previous month.
These are known prior to the monthly closing of the books and are thus recorded during the
monthly close (Reported Rebates). Additionally, Meridian calculates an estimate for
product sold to the distributor that is still on hand at the distributor. As stated in our
May 26, 2005 response to the SEC’s comment letter dated May 10, 2005, “Meridian
estimates its rebate provisions using historical experience. The following factors are
specifically included in the provision calculation:

o

Historical rebate data (reported by distributors to Meridian each month based on product
that is sold through to the end customer);

o

Historical distributor sales data (from Meridian internal records); and

o

Regression analysis"

Through the tracking of historical
distributor sales and Reported Rebates and regression analysis, an estimate of the rebates
that relate to product that is still on hand at the distributor is calculated (Estimated
Rebates). Thus, there are two components to the rebate accrual, the Reported Rebates and
Estimated Rebates. Typically, the distributors carry one month’s inventory. In the
rare case there is a significant deviation in distributor purchase patterns or distributor
sell through patterns, this is considered in the Estimated Rebate calculation. For these
reasons, there is minimal exposure to the effect that could result from using other
reasonably likely assumptions than those used in calculating the rebate provision or to
increases and decreases to the accrual related to sales made in prior years.

Below is a three-year roll-forward of
the rebate accrual.

     Rebate Accrual as of September 30, 2001

$    301,000

     Fiscal 2003 provision
        $ 4,837,000

     Fiscal 2003 rebates
       ($4,277,000
        )

     Rebate Accrual as of September 30, 2002
           $    861,000

     Fiscal 2003 provision
         $ 6,200,000

     Fiscal 2003 rebates
       ($5,978,000
        )

     Rebate Accrual as of September 30, 2003
         $ 1,082,000

     Fiscal 2004 provision
         $ 7,735,000

     Fiscal 2004 rebates
       ($7,500,000
        )

     Rebate Accrual as of September 30, 2004
         $ 1,318,000

There have been no material increases or
decreases in the accrual for sales relating to prior periods.

Comment No. 2-Major
Customers and Segment Data

SEC Staff Comment

It is still unclear how the products
within the US Diagnostic segment are similar or how the products within the Life Science
segment are similar. As such, for each of these segments, please describe the products
included in the segment, how they are similar and how additional disclosures (are) not
required by paragraph 37 of SAS 131. In your response please include at a minimum each of
the types of products mentioned in your response and in your MD&A under Results of
Operations. For the US Diagnostics segment your MD&A had mentioned respiratory, c.
difficile, rotavirus and parasitology. For the Life Science segment your response
mentioned bulk biologicals, antigens, antibodies and reagents and contract manufacturing.
If the products within the segment are dissimilar please provide disclosures that comply
with paragraph 37.

Meridian’s Response

Product sales reported within the US
Diagnostics segment are generated from in vitro (used outside of the body) diagnostic
products used in the diagnosis and treatment of infectious diseases. The US Diagnostics
segment sells these tests primarily to hospitals or reference laboratories.
Meridian’s diagnostic products detect parasites, bacteria and viruses in patient
samples (stool, urine, nasal/throat swab). For example, in the US Diagnostics segment,
Meridian sells test kits to detect respiratory infections such as influenza, RSV and
mycoplasma, products to diagnose infectious diseases caused by C.difficile, Rotavirus and
H. pylori viruses and bacteria and products to diagnose infectious diseases such as
cryptosporidium/giardia caused by parasites. These products are similar in that they all
are in vitro diagnostics used in the detection of infectious diseases.

Sales within the Life Science segment
are generated from the sale of bulk biologicals, which are typically antigens (proteins
capable of stimulating an immune response), antibodies (proteins that act against antigens
in an immune response) and reagents (substances used to measure or detect proteins). The
sales are generated from antibodies and antigens that are stocked for sale, made to order
or manufactured under formal contract manufacturing agreements. These products are similar
in that they relate to the manufacture of proteins that are sold to primarily to other
diagnostic manufacturers.

The discussion above illustrates the
product similarities within the US Diagnostics segment and the product similarities within
the Life Science Segment. On the basis of these product similarities within the segments,
we believe we have complied with Paragraph 37 of SFAS No. 141.

If you have any questions, please do
not hesitate to contact me.

Respectfully,

/s/ Melissa Lueke

Melissa Lueke

Vice President and Chief Financial Officer

/blh