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CORRESP
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      FHC July 2005 Correspondence re 2004 Form 10-KSB

    July
      7,
      2005

    SENT
      VIA
      EDGAR

    Mr.
      John
      Cash

    Accounting
      Branch Chief

    United
      States Securities and Exchange Commission

    Division
      of Corporation of Finance

    Washington,
      D.C. 20549

    Re:
      The Female Health Company Form 10-KSB for the year ended September 30,
      2004

      File No. 1-13602

    Dear
      Mr.
      Cash:

    The
      following is the response of the Female Health Company (the “Company”) to the
      comment in the letter of the staff of the Securities and Exchange Commission
      dated June 23, 2005 relating to the Company’s Form 10-KSB for the year ended
      September 30, 2004. For reference purposes, the text of the staff’s comment
      letter has been reproduced below together with the Company's response to the
      comment.

    Form
      10-KSB for the Year Ended September 30, 2004

    Note
      1.  Nature of Business and Significant Accounting Policies - Earnings
      per
      Share

    Comment
      No. 1

    We
      note
      your response to our prior comment three and your revised disclosure in the
      Form
      10-Q for the period ended March 31, 2005. However, in situations in which the
      computation of diluted EPS would have an anti-dilutive effect on earnings per
      share, the diluted weighted average common shares outstanding on the face of
      the
      income statement should be the same number as the basic weighted average shares
      outstanding. Further, the number of incremental shares issuable upon conversion
      of your convertible preferred stock or convertible debt and the exercise of
      stock options and warrants that were not included in the diluted earnings per
      share because their effect would be anti-dilutive should be disclosed in a
      footnote to the financial statements. Reference paragraphs 38 and 40c of SFAS
      128. Please revise as appropriate.

    Response
      to Comment No. 1

    As
      a
      result of the Company’s computation of diluted EPS having an anti-dilutive
      effect on earnings per share, the diluted weighted average common shares
      outstanding on the face of the income statement has the same number as the
      basic
      weighted average common shares outstanding in the Company's Form 10-KSB for
      the
      year ended September 30, 2004.

    Mr.
      John
      Cash

    Accounting
      Branch Chief

    July
      7,
      2005

    Page
      2

    We
      note
      that our revised disclosure in the Form 10-QSB for the period ended March 31,
      2005 was not consistent with your previous comment three.  We
      will
      prepare future filings in a manner that is consistent with your comment.
      Therefore, beginning with the Company’s Form 10-QSB for the quarterly period
      ended June 30, 2005, the Company will disclose the number of incremental shares
      issuable upon conversion of the Company’s convertible preferred stock,
      convertible debt and the exercise of stock options and warrants that are not
      included in diluted earnings per share because their effect would be
      anti-dilutive, in a footnote to the financial statements in accordance with
      paragraphs 38 and 40c of SFAS 128.

    Please
      contact me at (916) 773-1573 if you have any further questions on any responses
      to your comments.

    Best
      regards,

    The
      Female Health Company

    /s/
      Robert R. Zic

    Robert
      R.
      Zic

    Principal
      Accounting Officer