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SEC Company Response from VERU INC. (VERU) (CIK 0000863894) (VERU) — Feb 28, 2008

VERU INC. (VERU) (CIK 0000863894)
Date: Feb. 28, 2008 · CIK: 0000863894 · Accession: 0001042167-08-000041

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Confidence
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Summary

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Date
September 30, 2007
Author
The
Form
CORRESP
Company
VERU INC. (VERU) (CIK 0000863894)

Letter

United States Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549 Re: The Female Health Company Form 10-KSB for the year ended September 30, 2007 File No. 1-13602

Dear Mr. Cash:

The following are the responses of The Female Health Company (the "Company") to the comments in the letter of the staff of the Securities and Exchange Commission dated February 20, 2008 relating to the Company's Form 10-KSB for the year ended September 30, 2007. For reference purposes, the text of the staff's comment letter has been reproduced below with responses below for each numbered paragraph.

Form 10-KSB for the Year Ended September 30, 2007

Item 6. MD&A – Liquidity and Sources of Capital, page 20

Comment 1:

We have reviewed your response to our prior comment three. The enhanced disclosure you have included in your Form 10-Q for the period ended December 31, 2007 is not sufficiently detailed enough to enable a reader to understand the nature of an changes in your accounts receivable balance. Please revise future filings to include more specific and comprehensive disclosures.

Response to Comment No. 1:

The Company will expand the disclosure of its accounts receivable balance in MD&A in future filings. Below is a proposed form of such disclosure.

The Company's quarter-end accounts receivable balance is impacted by various factors besides rising sales levels. A primary factor is the Company's pattern of production and sales, which causes accounts receivable to spike near quarter end. The Company's U.K subsidiary produces product early in the quarter to be sold by its U.S. parent, thus ensuring that most sales to third parties occur in the second half of the quarter. The timing of large orders can have a significant impact on the quarter-end balance. The Company's standard credit terms vary from 30 to 90days, depending on the class of trade and customary terms within a territory, so accounts receivable is affected by the mix of purchasers within the quarter. As is typical in the Company's business, the Company may offer extended credit terms as a sales promotion. For the past twelve months, the Company's average days sales outstanding has been approximately days.

Note 1. Nature of Business and Significant Accounting Policies, page F-7

Deferred Grant Income, page F-9

Comment No. 2:

We have reviewed your response to our prior comment four. Please revise future filings to disclose the full impact that the government grants have had on your financial statements in a given period, including proceeds that are credited to income for expenses and proceeds that are released to income in connection with depreciation expense.

Response to Comment No. 2:

In future filings, the Company will disclose the full impact of government grants on the Company's financial statements in all applicable periods, including the amount of grant proceeds credited to income and the amount of grant proceeds released to income in connection with depreciation of the relevant assets.

Please contact me at (312) 595-9742 if you have any questions on any of the responses to your comments.

Best
regards,
The
Female Health Company

Show Raw Text
CORRESP
1
filename1.htm

    fhcfeb282008responsetosec.htm

    February 28,
      2008

    SENT
      VIA
      EDGAR

    Mr.
      John
      Cash

    Accounting
      Branch Chief

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    Washington,
      D.C. 20549

    Re:
The
      Female Health Company Form 10-KSB
      for the year ended September 30, 2007

           File
      No. 1-13602

    Dear
      Mr.
      Cash:

    The
      following are the responses of The Female Health Company (the "Company") to
      the
      comments in the letter of the staff of the Securities and Exchange Commission
      dated February 20, 2008 relating to the Company's Form 10-KSB for the year
      ended September 30, 2007.  For reference purposes, the text of
      the staff's comment letter has been reproduced below with responses below for
      each numbered paragraph.

    Form
      10-KSB for the Year
      Ended September 30, 2007

    Item
      6. MD&A – Liquidity
      and Sources of Capital, page 20

    Comment
      1:

    We
      have reviewed your response to our prior comment three.  The enhanced
      disclosure you have included in your Form 10-Q for the period ended December
      31,
      2007 is not sufficiently detailed enough to enable a reader to understand the
      nature of an changes in your accounts receivable balance.  Please
      revise future filings to include more specific and comprehensive
      disclosures.

    Response
      to Comment No.
      1:

    The
      Company will expand the disclosure of its accounts receivable balance in
      MD&A in future filings.  Below is a proposed form of such
      disclosure.

    The
      Company's quarter-end accounts receivable balance is impacted by various factors
      besides rising sales levels.  A primary factor is the Company's
      pattern of production and sales, which causes accounts receivable to spike
      near
      quarter end.  The Company's U.K subsidiary produces product early in
      the quarter to be sold by its U.S. parent, thus ensuring that most sales to
      third parties occur in the second half of the quarter.  The timing of
      large orders can have a significant impact on the quarter-end
      balance.  The Company's standard credit terms vary from 30 to 90days,
      depending on the class of trade and customary terms within a territory, so
      accounts receivable is affected by the mix of purchasers within the
      quarter.  As is typical in the Company's business, the Company may
      offer extended credit terms as a sales promotion.  For the past twelve
      months, the Company's average days sales outstanding has been approximately
      60
      days.

    Note
      1. Nature of Business
      and Significant Accounting Policies, page F-7

    Deferred
      Grant Income, page
      F-9

    Comment
      No. 2:

    We
      have reviewed your response to our prior comment four.  Please revise
      future filings to disclose the full impact that the government grants have
      had
      on your financial statements in a given period, including proceeds that are
      credited to income for expenses and proceeds that are released to income in
      connection with depreciation expense.

    Response
      to Comment No.
      2:

    In
      future
      filings, the Company will disclose the full impact of government grants on
      the
      Company's financial statements in all applicable periods, including the amount
      of grant proceeds credited to income and the amount of grant proceeds released
      to income in connection with depreciation of the relevant assets.

    Please
      contact me at (312) 595-9742 if you have any questions on any of the responses
      to your comments.

    Best
      regards,

    The
      Female Health Company

    /s/
      Donna
      Felch

    Donna
      Felch

    Vice
      President and Chief Financial Officer