SecProbe.io

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September 20, 2004

Via Facsimile and U.S. Mail

Gary P. Kreider, Esq.
Keating, Muething & Klekamp, P.L.L.
1400 Provident Tower
One East Fourth Street
Cincinnati, Ohio 45202

Re:	Hemagen Diagnostics, Inc.
	Reagents Applications, Inc.
	Amendment No. 1 to Schedule TO-I filed September 17, 2004
	File No. 5-50367

Dear Mr. Kreider:

We have the following comments on the above-referenced filing:

General

1. We note your revisions in response to prior comment number 2.  It
appears that the formula pricing portion of the offer will not be
based on the market price of the common stock through September 30,
2004, since the price will be calculated as of September 27, 2004.
Please advise or revise.

2. In the event that you are required to obtain a court order to
complete the offering, it appears that the effective date of the
closing will occur before the exchange offer has actually expired.
Please clarify the purpose for structuring the offer with this timing
mechanism and provide the legal and accounting support for using an
effective date which is prior to the expiration of the offer and the
actual issuance of the securities in the exchange.  Please also
explain any tax or other consequences to holders of structuring the
offer in this way.  For example, it appears possible that the issuance
of the exchange securities may not occur until calendar year 2005.
Would the holders incur tax consequences upon the effective date of
the offer or upon the issuance of the exchange securities?

3. In your disclosure, please explain the reason for the one-year
restriction on transferability of the common stock received in the
exchange offer.

Amendment to Release of Legal Claims by Tendering Outstanding Note
Holders

4. We note your revision in response to this comment; however, your
reference to the federal securities laws in the last clause of this
section is confusing.  Please revise.

Closing Comments

As appropriate, please respond to these comments by amending the
filing and submitting a response letter via EDGAR and "tagged" as
correspondence.  If you do not agree with a comment, please tell us
why in your response.  Please understand that we may have additional
comments after reviewing your responses to our comments.

Please direct any questions to me at (202) 942-2842.  You may also
reach me via facsimile at (202) 942-9638.  Please send all
correspondence to us at the following ZIP code:  20549-0303.

							Sincerely,

							Chris B. Edwards
							Attorney-Advisor
							Office of Mergers and Acquisitions

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