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CORRESP
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     SEC Comment Response Letter

Keating, Muething & Klekamp,
P. L.L.

   1400 Provident Tower . One East Fourth Street . Cincinnati, Ohio 45202

TEL 513.579.6400 . FAX 513.579.6457 . www.kmklaw.com

DIRECT DIAL: (513)
579-6411
FACSIMILE: (513) 579-6457
E-MAIL: GKREIDER@kmklaw.com

September 22, 2004

Via EDGAR and Facsimile
(202) 942-9638

Chris B. Edwards, Esq.

Attorney-Advisor
 Office of Mergers and Acquisitions

Division of Corporation Finance

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, DC 20549-0303

Re:
Hemagen
Diagnostics, Inc.
Reagents Applications, Inc.
Amendment No. 1 to Schedule TO-1

filed September 17, 2004
File No. 5-50367

Dear Mr. Edwards:

        On
behalf of the above-referenced companies, we are responding to the Staff’s comments
contained in the letter dated September 20, 2004 to the above-referenced Amendment No. 1
to Schedule TO-1. Accompanying this filing is an amended Schedule TO-1 and a revised
proposed Supplement No. 1 to Offering Memorandum which the companies propose to send all
holders of their 8% Senior Subordinated Secured Convertible Notes due 2005. Capitalized
terms in this letter have the meanings assigned to the terms in the Offering Memorandum
dated September 2, 2004 filed with the Schedule TO-1 referenced above.

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.

The
companies have revised the disclosure in Supplement No. 1 to the to make clear that the
price will be calculated based on the market price of the common stock through September
27, 2004 as opposed to September 30, 2004.

          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?

The
companies have added disclosure in Supplement No. 1 as a new second paragraph under, “
Effective Date of Exchange Offer” in response to the comment.

          3.

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

The
companies have added disclosure regarding the one-year restriction as a new third
paragraph under the section entitled, “Registration Rights; Restrictions on Resale of
Common Stock” in Supplement No. 1.

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.

The
companies have removed the reference to the federal securities laws in the last clause of
this section.

        If
you have any questions or need any additional information, please contact Mark Weiss of
our office (513-579-6599) or me.

Yours truly,

KEATING, MUETHING & KLEKAMP, P.L.L.

BY: /s/ Gary P. Kreider

      ——————————————

      Gary P. Kreider

Attachments

cc:
Mr. William Hales

Ms. Deborah Ricci

GPK:slh