SecProbe.io

Mail Stop 3030

December 4 , 2015

Via E -mail
Jeffrey A. Duchemin
Chief Executive Officer
Harvard Bioscience, Inc.
84 October Hill Road
Holliston, Massachusetts 01746

Re: Harvard Bioscience, Inc.
 Form 10-K for the fiscal year ended December 31, 2014
Filed March 12, 2015
File No. 001-33957

Dear Mr. Duchemin :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Item 7.  Management’s Discussion and Analysis, page 27

1. We note your  disclosure that your revenues during fiscal 201 4 increased as compared to
fiscal 201 3 and that the increase was the result of revenues from newly acquired business and
organic growth .  When individual line items disclosed in your statements of operations
significantly fluctuate in comparison to the comparable prior period, management should
quantify and disclose the nature of each item that caused the significant change.  For
example, please quantify each material factor  such as increases or decreases in r evenue from
business acquisitions or organic growth that affected your overall revenues .  For factors such
as organic growth, please discuss the underlying material causes for the increase in growth .
Please revise future filings in response to this commen t.  For further guidance, please refer to
Item 303 and the related instructions in Regulation S -K as well as SEC Interpretive Release
No. 34 -48960 (December 19, 2003).

Jeffrey A. Duchemin
Harvard Bioscience, Inc.
December 4, 2015
Page 2

 2. Where you attribute changes in gross margin to shifts in “product mix,” please revise
future filings to clarify how that mix has shifted such that gross margin was impacted.  In
addition, we note the reference on page 4 to five product families and the subsequent
disclosure describing those families.  Please revise future filings to include the disclosure
required by Regulation S -K Item 101(c)(1)(i).

3. We note your first risk factor references that a significant portion of your revenues are
derived from customers who are dependent for their funding upon grants from the NIH
and similar agencies  in other countries and your statements in your third quarter
conference call that the global slowdown in the academic and government research
markets due to budget constraints continues to be challenging.  In your future filings,
please disclose any known  trends affecting your business.  Please refer to Regulation  S-K
Item 303(a)(3)(ii).  Please also revise future filings to clarify the extent to which you are
indirectly dependent on such funding.  We note, for example, the references in your third
quarter  conference call to deriving 70% of your revenue from the academic and
government research market.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information  the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosur es they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal secur ities laws of the United States.

Jeffrey A. Duchemin
Harvard Bioscience, Inc.
December 4, 2015
Page 3

 Please contact Tim Buchmiller at (202) 551 -3635  or Geoff Kruczek, Senior Attorney, at
(202) 551 -3641  with any questions.

Sincerely,

 /s/ Geoff Kruczek for

Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: Chad J. Burns,  Esq.
 Burns & Levinson LLC