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SEC Comment Letter for VERU INC. (VERU) (CIK 0000863894) (VERU) — Feb 20, 2008

VERU INC. (VERU) (CIK 0000863894)
Date: Feb. 20, 2008 · CIK: 0000863894 · Accession: 0000000000-08-009077

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Document Type
Confidence
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Reasoning

Referenced dates: February 11, 2008

Date
February 20, 2008
Author
Not clearly detected
Form
UPLOAD
Company
VERU INC. (VERU) (CIK 0000863894)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE Mail Stop 7010 February 20, 2008 Ms. Donna Felch The Female Health Company 515 North State Street, Suite 2225 Chicago, Illinois 60610

RE: The Female Health Company Form 10-KSB for the fiscal year ended September 30, 2007 Filed December 21, 2007 File # 1-13602

Dear Ms. Felch: We have reviewed your response letter dated February 11, 2008 and have the following additional comments. If you disagree , we will consider your explanation as to why our comment is inapplicable. In some of our comments, we may ask you to provide us with supplemental information so we ma y better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Form 10-KSB for the fiscal year ended September 20, 2007

Item 6. MD&A - Liquidity and Sources of Capital, page 20 1. We have reviewed your response to our prior comment three. The enhanced disclosure you have included in your Fo rm 10-Q for the period ended December 31, 2007 is not sufficiently detailed enough to enable a reader to understand the nature of and changes in your accounts rece ivable balance. Please revise future filings to include more specific and comprehensive disclosures.

Note 1. Nature of Business and Signif icant Accounting Policies, page F-7 Deferred Grant Income, page F-9 2. We have reviewed your response to our pr ior comment four. Please revise future filings to disclose the full impact th at the government grants have had on your financial statements in a given period, including proceeds that are credited to

Ms. Donna Felch The Female Health Company February 20, 2008 Page 2 income for expenses and proceeds that are released to income in connection with depreciation expense.

* * * *

As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested supplemental 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. If you have any questions regarding these co mments, please direct them to Tricia Armelin, Staff Accountant, at (202) 551-3747, Anne McConnell, Senior Accountant, at (202) 551-3709 or, in their absence, to the undersigned at (202) 551-3768.

S i n c e r e l y ,

John Cash A c c o u n t i n g B r a n c h C h i e f

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

 Mail Stop 7010
February 20, 2008

Ms. Donna Felch
The Female Health Company 515 North State Street, Suite 2225 Chicago, Illinois 60610

 RE: The Female Health Company
Form 10-KSB for the fiscal year ended September 30, 2007
  Filed December 21, 2007
File # 1-13602

   Dear Ms. Felch:
We have reviewed your response letter  dated February 11, 2008 and have the
following additional comments.  If you disagree , we will consider your explanation as to
why our comment is inapplicable.  In some of our comments, we may ask you to provide
us with supplemental information so we ma y better understand your disclosure.  After
reviewing this information, we may or may not raise additional comments.
 Form 10-KSB for the fiscal year ended September 20, 2007

Item 6. MD&A - Liquidity and Sources of Capital, page 20
1. We have reviewed your response to our prior comment three.  The enhanced
disclosure you have included in your Fo rm 10-Q for the period ended December
31, 2007 is not sufficiently detailed enough to enable a reader to understand the
nature of and changes in your accounts rece ivable balance.  Please revise future
filings to include more specific and comprehensive disclosures.

Note 1. Nature of Business and Signif icant Accounting Policies, page F-7
Deferred Grant Income, page F-9
2. We have reviewed your response to our pr ior comment four.  Please revise future
filings to disclose the full impact th at the government grants have had on your
financial statements in a given period, including proceeds that are credited to

Ms. Donna Felch
The Female Health Company February 20, 2008 Page 2
income for expenses and proceeds that are released to income in connection with
depreciation expense.

*    *    *    *

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a letter that keys your
responses to our comments and provides any requested supplemental 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.
If you have any questions regarding these co mments, please direct them to Tricia
Armelin, Staff Accountant, at  (202) 551-3747, Anne McConnell,  Senior Accountant, at
(202) 551-3709 or, in their absence, to the undersigned at (202) 551-3768.

         S i n c e r e l y ,

        John Cash        A c c o u n t i n g  B r a n c h  C h i e f