SecProbe.io

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 APYX
MEDICAL CORPORATION

 5115
Ulmerton Road

 Clearwater,
Florida 33760

 December
12, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F. St., N.E.

 Washington,
D.C. 20549

 Re:
 Apyx
 Medical Corporation
 Registration
 Statement on Form S-3
 File
 No. 333-291865
 Request
 for Acceleration

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Apyx Medical Corporation hereby requests the acceleration of the effective
date of the above-referenced Registration Statement on Form S-3 (File No. 333-291865) so that it will become effective on Tuesday,
December 16, 2025, at 4:30 p.m., Eastern Time, or as soon thereafter as practicable.

 Please
call Adam Silvers or Dominick Ragno of Ruskin Moscou Faltischek P.C. at (516) 663-6600 to provide notice of the effectiveness of the
Registration Statement.

 Very
 truly yours,

 Apyx
 Medical Corporation

 By:
 /s/
 Matt Hill

 Matt
 Hill, Chief Financial Officer

 cc:
 Adam
 Silvers, Ruskin Moscou Faltischek P.C.

 Dominick
 Ragno, Ruskin Moscou Faltischek P.C.

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apyx_s-3xaccelerationxre

      November 30, 2022  VIA EDGAR  United States Securities and Exchange Commission   Division of Corporation Finance   100 F. St., N.E.   Washington, D.C. 20549     Re: Request for Acceleration of Effectiveness of Registration Statement on Form S-3 (File  No.  333-268532)   Ladies and Gentlemen:     Pursuant to Rule 461 under the Securities Act of 1933, as amended, Apyx Medical Corporation (the  “Registrant”) hereby requests the acceleration of the effective date of the above-referenced Registration  Statement on Form S-3 (File No.  333-268532) (the “Registration Statement”) so that it will become  effective on Friday, December 2, 2022 at 4:30 p.m., Eastern Time, or as soon thereafter as practicable.     The Registrant hereby authorizes Adam P. Silvers, of Ruskin Moscou Faltischek, P.C., to orally  modify or withdraw this request for acceleration.    Please contact Mr. Silvers at (516) 663-6519, or in his absence Dominick P. Ragno, of Ruskin  Moscou Faltischek, P.C., at (516) 663-6614, to provide notice of effectiveness of the Registration  Statement, or if you have any questions or comments relating to this request.     We also respectfully request that a copy of the written order from the United States Securities and  Exchange Commission verifying the effective time and date of such Registration Statement be sent to  Ruskin Moscou Faltischek, P.C., attention: Adam P. Silvers, via email at asilvers@rmfpc.com.    Very truly yours,    Apyx Medical Corporation      By:   /s/  Tara Semb          Name:  Title:    Tara Semb  Chief Financial Officer

United States securities and exchange commission logo
November 29, 2022
Charles D. Goodwin II
Chief Executive Officer
Apyx Medical Corp.
5115 Ulmerton Road
Clearwater, FL 33760
Re:Apyx Medical Corp.
Registration Statement on Form S-3
Filed November 22, 2022
File No. 333-268532
Dear Charles D. Goodwin II:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Benjamin Richie at 202-551-7857 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Adam P. Silvers, Esq.

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		Document

CORRESP

May 16, 2018

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. St., N.E.

Washington, D.C. 20549

 Re:

 Request for Acceleration of Effectiveness of Registration Statement on Form S-3 (File No.  333-224677) of Bovie Medical Corporation (the “Registrant”)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, and on behalf of the Registrant, we hereby request that the effectiveness of the above-captioned Registration Statement (the “Registration Statement”) be accelerated so that such Registration Statement will become effective on Wednesday, May 16, 2018 at 4:00 p.m., Eastern Time, or as soon thereafter as practicable.

The Registrant hereby authorizes Adam P. Silvers, of Ruskin Moscou Faltischek, P.C., to orally modify or withdraw this request for acceleration.

We request that we be notified of such effectiveness by a telephone call to Mr. Silvers at (516) 663-6519, or in his absence Michael S. Williams, of Ruskin Moscou Faltischek, P.C., at (516) 663-6657. We also respectfully request that a copy of the written order from the Commission verifying the effective time and date of such Registration Statement be sent to Ruskin Moscou Faltischek, P.C., attention: Adam P. Silvers, via email at asilvers@rmfpc.com.

 Very truly yours,

BOVIE MEDICAL CORPORATION

 By:

 /s/ JAY D. EWERS

 Name:

Title:

 Jay D. Ewers

Chief Financial Officer

763495

Mail Stop 3030
May 9, 2018

Charles D. Goodwin, II
Chief Executive Officer
Bovie Medical Corporation
5115 Ulmerton Road
Clearwater, Florida 33760

Re: Bovie Medical Corporation
  Registration Statement on Form S-3
Filed  May 4 , 2018
  File No.  333-224677

Dear  Mr. Goodwin :

This is to advise you that we have not reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please  contact Tim Buchmiller  at (202) 551 -3635  with any questions.

Sincerely,

/s/ Tim Buchmiller  for

Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: Adam P. Silvers, Esq.
Ruskin Moscou Faltischek, P.C

August 23, 2012

Via E -mail
Gary D. Pickett
Chief Financial Officer
Bovie Medical Corporation
734 Walt Whitman Rd.
Melville, NY 11717

Re: Bovie Medical Corporation
Form 10 -K for fiscal  year ended December 31, 2011
Filed March 29, 2012
File No. 001-31885

Dear Mr. Pickett :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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 securities laws of the United States.  We urge all per sons 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 rules require.

Sincerely,

 /s/ Louis Rambo for

Amanda Ra vitz
Assistant Director

cc (by E -mail): Adam Silvers, Esq.

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    boviecommentletter.htm

Writer's Direct Dial:  (516) 663-6519

Writer's Direct Fax:  (516) 663-6643

Writer's E-mail:  asilvers@rmfpc.com

August 16, 2012

Amanda Ravitz

Assistant Director

Division of Corporate Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re:      Bovie Medical Corporation

Form 10-K for fiscal year ended December 31, 2011

Filed March 29, 2012

File No. 001-31885

Dear Ms. Ravitz:

On behalf of Bovie Medical Corporation (the “Company”), we submit the following responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) set forth in the Staff’s letter dated July 26, 2012 (the “Comment Letter”) regarding the Company’s Form 10-K for fiscal year ended December 31, 2011, filed March 29, 2012 (File No. 001-31885). The comments from the Comment Letter are included below in bold. The Company’s response follows each comment. The Company shall file the following in response to the Staff’s comments: (i) Amendment No. 1 to the Form 10-K for the fiscal year ended December 31, 2011 (“Amended Form 10-K”), and (ii) Form 8-K/A (“Amended Form 8-K,” and together with the Amended Form 10-K, the “Amendments”), which includes the amendments described herein.

U.S. Securities and Exchange Commission

August 16, 2012

Page 2

Intellectual Property, page 5

1.

We note your disclosure on page 5 that some of your patents are nearing the end their term. In future filings, please disclose the duration of your material patents, and the nature of the claims to which those patents relate. Refer to Regulation S-K Item 101(h)(4)(vii).

Response:  In response to the comment, the Company advises the Staff that it will disclose in future filings, the duration of its material patents, and the nature of the claims to which those patents relate.

Compensation of Named Executive Officers, page 39

2.

With a view toward amended disclosure, please tell us how you determined not to discuss in this section the penalties against Mr. Citronowicz referenced in your Form 8-K filed November 29, 2011. We note, for example, the forfeiture of stock options mentioned in that document. See Regulation S-K Item 402(o)(2).

Response:  In response to the comment, the Company will amend the disclosure provided on page 39 discussing the penalties against Mr. Citronowicz upon the filing of the Amended Form 10-K.

3.

Please reconcile the information in the table on page 41 regarding Messrs. Pickett and Keen with the information in the table on page 21 of your definitive proxy statement filed May 22, 2012.

Response:  In response to the comment, the Company will amend the information provided in the table on page 41 regarding Messrs. Pickett and Keen upon the filing of the Amended Form 10-K.

Signatures, page 47

4.

In your future filings, please indicate who is signing in the capacity of principal accounting officer or controller. Refer to Form 10-K, Signatures, and comment 12 from our letter dated August 25, 2009.

Response:  In response to the comment, the Company advises the Staff that it will indicate in future filings, who is signing in the capacity of the principal accounting officer or controller.

U.S. Securities and Exchange Commission

August 16, 2012

Page 3

Exhibits

5.

We note that multiple exhibits were omitted from Exhibit 99.1 to your Form 8-K on February 28, 2012. Please file those exhibits or tell us how you determined that these exhibits are not required to be filed.

Response:  In response to the comment, the Company will include all necessary exhibits to Exhibit 99.1 upon the filing of the Amended Form 8-K.

Definitive Proxy Statement on Schedule 14A filed May 22, 2012

6.

On pages 5-6 of your definitive proxy statement, you state that broker non-votes will have the same effect as an “against” vote with respect to proposals two and three and that each of those proposals requires “for” votes from the holders of a majority of shares present and entitled to vote in person or by proxy. Given this, please tell us how you determined the voting results you disclosed in the Form 8-K filed July 13, 2012, including how you determined that proposals two and three were approved by the required number of votes “for” those proposals.

Response:  In response to the comment with respect to proposal two (approval of the Company’s 2012 Share Incentive Plan), please note that the voting results disclosed in the Company’s Form 8-K, filed July 13, 2012 (7,471,354 “for,” 1,861,926 “against,” and 20,735 “abstain”) reflected the inclusion of broker non-votes for quorum but not for voting purposes.  This is consistent with Delaware and applicable New York Stock Exchange rules. Under Delaware law, in all matters other than the election of directors, the affirmative vote of the majority of shares present in person or represented by proxy at a stockholders meeting and entitled to vote on the subject matter shall be the act of the stockholders.  See DGCL § 216(2).  A broker non-vote occurs when the broker cannot vote any shares on a proposal in the absence of voting instructions from the beneficial owner (i.e. uninstructed shares) and the broker is not entitled to vote on those matters without instruction.  Pursuant to New York Stock Exchange Rule 452, brokers are only permitted to vote uninstructed shares on “routine matters.”  Broker non-votes with respect to “non-routine” matters are considered present for quorum purposes but are not entitled to vote on such matters.  Thus, with respect to proposal two, broker non-votes were treated as present for quorum purposes but were not given any effect for voting purposes.

In response to the comment with respect to proposal three (ratification of the Company’s auditors), please note that the voting results disclosed in the Company’s Form 8-K, filed July 13, 2012 (14,803,724 “for,” 482,117 “against,” and 227,993 “abstain”) do not reflect any broker non-votes because auditor ratification is, under applicable New York Stock Exchange rules, considered a “routine” item for which brokers are permitted to vote in the absence of shareholder instruction.  This is also consistent with applicable Delaware law as noted above.

U.S. Securities and Exchange Commission

August 16, 2012

Page 4

The Company advises the Staff that the votes with respect to proposals two and three were tabulated as described on page 4 of the Definitive Proxy Statement on Schedule 14A, filed May 22, 2012 (the “Proxy Statement”).  On page 4, the Proxy Statement states that “abstentions and broker non-votes will count for purposes of determining whether a quorum exists, but not for voting purposes.” The Company notes an inconsistency in the language on page 6 of the Proxy Statement that “broker non-votes will have the same effect as an ‘Against’ vote.”

****************

The Staff requested that the Company provide the following representations in its response to the Staff comments. In connection with the Amendments, the Company acknowledges that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in the Amendments; (ii) Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the SEC from taking any action with respect to the Amendments; and (iii) the Company may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.

We believe the foregoing information and proposed changes to the Company’s filings respond fully to the comments raised in the Comment Letter.  If you have any questions or require additional information, please contact the undersigned by telephone at (516) 663-6519.

Very truly yours,

/s/ Adam P. Silvers

ADAM P. SILVERS, ESQ.

For the Firm

cc:        Gary D. Picket,

Chief Financial Officer

July 26, 2012

Via E -mail
Gary D. Pickett
Chief Financial Officer
Bovie Medical Corporation
734 Walt Whitman Rd.
Melville, NY 11717

Re: Bovie Medical Corporation
 Form 10-K for fiscal year ended December 31, 2011
Filed March 29, 2012
File No. 001 -31885

Dear Mr. Pickett :

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 this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have  additional comments.

Intellectual Property, page 5

1. We note your disclosure on page 5 that some of your patents are nearing the end their
term.  In f uture filing s, please disclose the duration of your material patents,  and the
nature of the claims to which those patents relate.  Refer to Regulation S -K Item
101(h)(4)(vii).

Compensation of Named Executive Officers, page 39

2. With a view toward amended disclosure, please tell us how you determined not to discuss
in thi s section the penalties against Mr. Citronowicz referenced in your Form 8 -K filed
November 29, 2011.  We note, for example, the forfeiture of stock options mentioned in
that document.  See Regulation S -K Item 402(o)(2).

Gary D. Pickett
Bovie Medical Corporation
July 26, 2012
Page 2

 3. Please reconcile the information i n the table on page 41 regarding Messrs. Pickett and
Keen with the information in the table on page 21 of your definitive proxy  statement filed
May 22, 2012.

Signatures, page 47

4. In your future filings, please indicate who is signing in the capacity of p rincipal
accounting officer or controller.  Refer to Form 10 -K, Signatures , and comment 12 from
our letter dated August 25, 2009.

Exhibits

5. We note that multiple exhibits were omitted from Exhibit 99.1 to your Form 8 -K on
February 28, 2012.  Please file those exhibits or tell us how you determined that these
exhibits are not required to be filed.

Definitive Proxy Statement on Schedule 14A filed May 22, 2012

6. On pages 5 -6 of your definitive proxy statement, you state that broker non -votes will
have the same effect as an “against” vote with respect to proposals two and three and that
each of those proposals requires “for” votes from the holders of a majority of shares
present and entitled to vote in person or by proxy.  Given this, please tell us how you
determined the voting results you disclosed in the Form 8 -K filed July 13, 2012,
including how you determined that proposals two and three were approved by the
required number of votes “for” those proposals.

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 appli cable 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 disclosures they have made.

 In responding to our commen ts, 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 securities laws of the United States.

Gary D. Pickett
Bovie Medical Corporation
July 26, 2012
Page 3

 Please contac t Louis Rambo  at (202) 551 -3289  or Geoff Kruczek  at (202) 551 -3641  with
any questions.

Sincerely,

 /s/ Geoff Kruczek for

Amanda Ravitz
Assistant Director

cc (by E -mail):  Adam Silvers, Esq.

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3030
February 19, 2010
  Andrew Makrides President, Chairman of the Board Bovie Medical Corporation 734 Walt Whitman Road Melville, New York 11747
 Re: Bovie Medical Corporation
  Form 10-K for the fiscal year ended December 31, 2008   Filed on  March 16, 2009   File No. 1-31885

 Dear Mr. Makrides:   We have completed our review of your Form 10-K and related filings and do not, at this time, have
any further comments.             S i n c e r e l y ,                 B r i a n  C a s c i o           A c c o u n t i n g  B r a n c h  C h i e f

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3030
                             November 20, 2009   Via U S Mail and FAX [(631) 421-5821]

 Andrew Makrides President, Chairman of the Board Bovie Medical Corporation 734 Walt Whitman Road Melville, New York 11747
 Re: Bovie Medical Corporation
  Amendment No. 2 to Form 10-K for the fiscal year ended December 31, 2008   Filed on November 9, 2009   File No. 1-31885

Dear Mr. Makrides:
We have reviewed your filing and have the following comments.  Where indicated, we
think you should revise your documents in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  After reviewing this information, we may raise additional comments.   Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Andrew Makrides Bovie Medical Corporation November 20, 2009 Page 2
Amendment No. 2 to Form 10-K for the fiscal year ended December 31, 2008

Item 15.  Exhibits
 1. Please tell us when you intend to respond to our comments issued on your confidential treatment application.
  Form 10-Q for the quarter ended September 30, 2009

 Statements of Cash Flows,  page 6

 2. We see that in the column for the nine months ended September 30, 2008 you have presented information for the six months ended June 30, 2008.  In an amendment, please present the comparable period of 2008.
 Salaries, page 19

 3. In future filings, please expand the disclosure to include all of the material increases and offsetting factors that explain the variances in your expenses.  For example, from the first six bullets on page 20 relating to the salary expenses for the quarterly period ended September 30, 2009 you have only accounted for $7,000 of the $32,000 increase in salaries.  Similarly, for the nine months ended September 30, 2009, you disclose that your salary expenses increased by a total of $51,000, but the disclosed increases and offsetting factors only explain $12,000 of the total variance for that period.

Selling, General & Administrative Expenses, page 20

4. In future filings, please expand the disclosure to include all of the material increases and offsetting factors that explain the variances in your expenses.  For example, from the bullet points on page 20 relating to your SG&A expenses for the quarterly period ended September 30, 2009 you have only accounted for $191,000 of the $251,000 increase in those expenses.  In addition, please disclose why expenses increased or decreased.  For example, we note the disclosure of decreased expenses in the last three bullets on page 20; however, you did not disclose the reasons why these expenses decreased.

Mr. Andrew Makrides Bovie Medical Corporation November 20, 2009 Page 3
Item 6.  Exhibits

5. Please tell us where you filed as exhibits your October 2009 employment agreements mentioned on page 14.

As appropriate, please respond to these comments within 10 business days or tell us
when you will provide us with a response.  Please furnish a response letter that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Jeanne Bennett at (202) 551-3606, or me at (202) 551-3676 if you have
questions regarding comments on the financial statements and related matters.  Please contact Thomas Jones at (202) 551-3602 or Timothy Bu chmiller, Senior Attorney at (202) 551-3635
with any other questions.

Sincerely,

        B r i a n  C a s c i o          A c c o u n t i n g  B r a n c h  C h i e f

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3030
                             October 15, 2009   Via U S Mail and FAX [(631) 421-5821]

 Andrew Makrides President, Chairman of the Board Bovie Medical Corporation 734 Walt Whitman Road Melville, New York 11747
 Re: Bovie Medical Corporation
  Amendment No. 1 to Form 10-K for the fiscal year ended December 31, 2008   Filed on September 18, 2009   File No. 1-31885

Dear Mr. Makrides:
We have reviewed your filing and have the following comments.  Where indicated, we
think you should revise your documents in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  After reviewing this information, we may raise additional comments.   Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Andrew Makrides Bovie Medical Corporation October 15, 2009 Page 2
Amendment No. 1 to Form 10-K for December 31, 2008

Item 1A.  Risk Factors, page 1
 1. We note your response to prior comment 2.  It is unclear whether the disclosure under the captions “Manufacturing” and “International” on page 6 is in response to Item 101 or Item 503 of Regulation S-K.  In future filings:
• If the disclosure is in response to Item 101, provide the disclosure under Item 1 of your Form 10-K; or
• If the disclosure is in response to Item 503, revise the titles of the captions under Item 1A to highlight the risk.
 Signatures, page 6

 2. We note your response to prior comment 12.  Your controller or principal accounting officer should also sign the report below the second paragraph required on the Signatures page.  Please revise.
 Exhibit Index, page 7

 3. We note the exhibits you filed in response to prior comment 14.  Please be advised that comments on your confidential treatment application will be issued in a separate letter.
 4. We note your response to the first and second bullets of prior comment 14.  Please file the complete agreement.  We note the following:
• Exhibit A of exhibit 10.12 is missing;
• Exhibit A of exhibit 10.14 is missing; and
• Exhibits A, B, C and D of exhibit 10.15 are missing.

Item 8.  Financial Statements and Supplementary Data

Note 13.  Gain from Contract Settlement, page F-21

5. We note your response to our prior comment 8.  Please explain to us how you determined fair value of the assets acquired in the nonmonetary exchange.  Provide the methodology

Mr. Andrew Makrides Bovie Medical Corporation October 15, 2009 Page 3
and assumptions used, and the basis for your projections.  Please also indicate how you considered the license granted to Boston Scientific in your valuation and why you believe that this is incidental to the transaction.

6. Please tell us how your accounting complies with FASB ASC 845-10-30-3 and 8, which
indicates that if you are unable to determine fair value within reasonable limits, a nonmonetary exchange should be measured based on the recorded amount of the nonmonetary assets transferred.
 7. Since the distribution agreement was previously considered part of your operations and any related revenues and expenses were included in operating income, please explain why the gain from settlement of the distribution agreement is not included in operations.  Please explain how your presentation of this gain in your income statement is consistent with the guidance in Question 2 of SAB Topic 5P, which indicates that items related to operations should be classified in operations.
 General

 8. As requested in our letter dated August 25, 2009, please provide, in writing, a 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 securities laws of the United States.

As appropriate, please respond to these comments within 10 business days or tell us
when you will provide us with a response.  Please furnish a response letter that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your responses to our comments.

Mr. Andrew Makrides Bovie Medical Corporation October 15, 2009 Page 4
You may contact Jeanne Bennett at (202) 551-3606, or me at (202) 551-3676 if you have
questions regarding comments on the financial statements and related matters.  Please contact Thomas Jones at (202) 551-3602 or Timothy Bu chmiller, Senior Attorney at (202) 551-3635
with any other questions.

Sincerely,

        B r i a n  C a s c i o          A c c o u n t i n g  B r a n c h  C h i e f

CORRESP
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    BOVIE
MEDICAL CORPORATION

    734
WALT WHITMAN ROAD

    SUITE
207

    MELVILLE,
NY 11747

    September
17, 2009

    Securities
and Exchange Commission

    Washington,
D.C 20549

    Attention:
Timothy Buchmiller

    Division
of Corporation Finance

    Mail Stop
3030

    Re:           Bovie
Medical Corporation (the “Company”)

    Form 10K for Fiscal Year

    Ended December 31, 2008

    Filed on March 16, 2009

    File No. 1-31885

    Gentlemen:

    At the
request of the staff in its comments to our Form 10-K Annual Report for the year
ended December 31, 2008, Bovie Medical Corporation hereby acknowledges
that:

              (a)

              The
      Company is responsible for the adequacy and accuracy of the disclosure in
      our filing;

              (b)

              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;

              (c)

              The
      Company may not assert staff comments as a defense in any proceeding
      initiated by the Commission or any person under the federal securities
      laws of the United States.

              Very
      truly yours,

              BOVIE
      MEDICAL CORPORATION

              BY:

              /S/ Andrew Makrides

              Andrew
      Makrides, President

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
          Mail Stop 3030

  August 25, 2009

Via U S Mail and FAX [(631) 421-5821]

Andrew Makrides President, Chairman of the Board Bovie Medical Corporation 734 Walt Whitman Road Melville, New York 11747
 Re: Bovie Medical Corporation
  Form 10-K for the fiscal year ended December 31, 2008   Filed on  March 16, 2009   File No. 1-31885

Dear Mr. Makrides:
We have reviewed your filings and have the following comments.   Where
indicated, we think you should revise your documents in response to these comments with the Commission.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Andrew Makrides
Bovie Medical Corporation
August 25, 2009 Page 2  Form 10-K for the fiscal year ended December 31, 2008

 Item 1.  Business

 Suture Removal Device, page 5

 1. In your future filings, please discuss in greater detail the feedback from the initial studies.  Also, discuss the status of the redesign of the device.  We note that you included identical disclosure of the suture removal device on page 4 of your Form 10-K for the fiscal year ended December 31, 2007.
 2. In your future applicable filings, please ensure that you have included all of the disclosures required by Item 101 of Regulation S-K under Item 1 of your Form 10-K.  For example, we note the disclosures regarding your customers, competition and government regulation currently appear on pages 5 through 8 under Item 1A rather than under Item 1.
 Item 1A.  Risk Factors, page 5

 3. Please revise the titles of the risk factors to adequately describe the risk.  See Item 503(c) of Regulation S-K.
 Item 4.  Submission of Matters to a Vote of Security Holders, page 10

 4. In your future filings, please include all of the information required by Item 4 of Form 10-K as this information cannot be incorporated by reference from your proxy statement, and would not contain the information required by Item 4(c) with respect to the number votes on each matter.
 Item 5.  Market for Registrant’s Common Equity and Related Stockholder Matters,
page 11
 5. In your future filings, please include the disclosure required by Item 701 of Regulation S-K.  For example, we note the disclosure on page F-6 of the issuance of shares; however, it does not appear that you have provided the disclosure required by Item 701 in this or any of your other Exchange Act filings.
 2008 Compared with 2007, page 16

 6. We note your sales declined 2.4% primarily driven by the 5.3% decline in domestic sales.  In you future filings, please discuss and analyze the primary factors driving any significant changes in the line items being compared period over period.  For example, your disclosure should indicate why you have

Mr. Andrew Makrides
Bovie Medical Corporation
August 25, 2009 Page 3
experienced any significant increases or decreases in international or domestic sales for the periods compared.
 Liquidity and Capital Resources, page 19

 7. We note from your disclosure in this section that your net cash provided by operating activities was materially affected by your build up in inventories and trade receivables.  In your applicable future filings, please disclose the trends driving your cash requirements for increasing inventory.  For example, your disclosure should address the sales, business or product trends that are driving your need to increase inventory.
 Item 8.  Financial Statements and Supplementary Data, page 24

 Note 13.  Gain from Contract Settlement, page F-21

 8. We note that the gain on settlement of your contract with Boston Scientific is significant, representing 82% of net income for 2008.  Please tell us the nature of the settlement and the related accounting treatment.  Clarify the basis in GAAP for recognizing the entire gain in fiscal 2008, and explain why this should not be recorded over the term of the new license agreement.  Please tell us whether there are any future performance obligations related to this settlement.  In addition, tell us why you have included the gain in other income (expense), rather than in income from operations.
 Item 12.  Security Ownership of Certain Beneficial Owners and Management, page 36

 9. In your future filings, please provide the disclosure required by Item 201(d) of Regulation S-K.
 Item 13.  Certain Relationships and Related Transactions, page 38

 10. In future filings, please provide the disclosure required by Item 404(b) of Regulation S-K.
 Signatures, page 40

 11. We note your signatures page indicates the incorrect year.  Please revise.
 12. Your principal executive officer or officers, principal financial officer or officers, controller or principal accounting officer, and at least a majority of the board of directors should sign the report below the second paragraph required on the

Mr. Andrew Makrides
Bovie Medical Corporation
August 25, 2009 Page 4
Signatures page.  We note that no person has signed the report below the second paragraph.  Please revise.
 Exhibit Index, page F-26

 13. In future filings, please expand the exhibit index to list documents filed as part of the report as required by Item 15 of Regulation S-K.
 14. Please tell us where you filed as exhibits the following:

• The agreements with Boston Scientific Corporation mentioned in the third and fourth paragraphs on page 3;
• The October 2006 agreement to acquire the assets of Lican Developments LTD mentioned in the fifth paragraph on page 5;
• The amended manufacturing agreement with Arthrex Corporation mentioned in the first paragraph on page 6;
• The amended employment agreements with Messrs. Makrides, Saron and Citronowicz subsequent to your January 6, 2004 amended employment agreements with them.  We note the disclosure on page 33 that the agreements have been extended to January 2012; and
• The October 10, 2006 agreement with Mr. Livneh and the June 18, 2007 employment contract with Mr. Pickett mentioned in the first two paragraphs on page 34.

If you did not file an agreement as an exhibit, please provide us with your analysis as to why the agreement does not need to be filed as required by Item 601(b)(10) of Regulation S-K.
 15. Please tell us where you filed as an exhibit the January 2006 agreement mentioned on page 4.  It appears from the exhibit index of your Form 10-K for the fiscal year ended December 31, 2007 that you filed the agreement as Exhibit 10.11 to the Form 10-K; however, the agreement was not filed as an exhibit to that filing.
 Form 10-Q for the quarter ended March 31, 2009; and

Form 10-Q for the quarter ended June 30, 2009
 16. We note that the certifications filed pursuant to Exchange Act Rule 13a-14(a) are not in the exact form prescribed by Item 601(b)(31) of Regulation S-K.  Specifically, we note that you replaced the word “report” with “annual report” in paragraphs 2 and 3 of your Form 10-Q for the quarter ended March 31, 2009.  In

Mr. Andrew Makrides
Bovie Medical Corporation
August 25, 2009 Page 5
your future filings, please ensure that the certifications conform to the exact wording required by Item 601(b)(31) of Regulation S-K.

As appropriate, please respond to these comments within 10 business days or tell
us when you will provide us with a response.  Please furnish a response letter that keys your responses to our comments and provides the requested information.  Confirm that you will comply with these comments in all future filings with the Commission.  Detailed response letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your responses to our comments and the requested information.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing reviewed by the staff to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed decision.  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 disclosures they have made.
In connection with responding to our comments, please provide, in writing, a
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 securities laws of the United States.

In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.

Mr. Andrew Makrides
Bovie Medical Corporation August 25, 2009 Page 6
You may contact Jeanne Bennett at ( 202) 551-3606, or Brian Cascio, Accounting
Branch Chief at (202) 551-3676 if you have questions regarding comments on the financial statements and related matters.  Please contact Thomas Jones at (202) 551-3602 or me at (202) 551-3635 with any other questions.
Sincerely,

       Timothy Buchmiller         S e n i o r  A t t o r n e y

Mail Stop  6010

May 2, 2007

Andrew Makrides, President
Bovie Medical Corporation
734 Walt Whitman Road
Melville, New York 11747

Via U S Mail and FAX [ (631) 421-5821 ]

 Re: Bovie Medical Corporation
  Form 8-K for Item 4.01
  Filed April 27, 2007
  File No. 0-12183

Dear  Mr. Makrides :
 We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comments are inapplicable
or a revision is unnecessary.  After reviewi ng this information, we may raise additional
comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call the applicable sta ff person at the telephone number listed at the
end of this letter.

Mr. Andrew Makrides
Bovie Medical Corporation
May 2, 2007
Page 2

Form 8-K Filed April 27, 2007

1. Please amend your report to include all of  the information required by Item 304 of
Regulation S-B.  Item 304(a)(1)(ii) of Regulatio n S-B requires that you state whether the
auditors' report on your financial statements for either of the past two years contained an
adverse opinion or a disclaimer of opinion or was qualified or modified as to uncertainty,
audit scope or accounting principles and, if so, a description of the nature of each adverse
opinion, disclaimer of opinion, m odification or qualification.

2. Please disclose the specific date on wh ich your former auditor passed away, and
disclose whether, during your two most rece nt fiscal years and any subsequent interim
period before that date:

- you had any disagreement(s) with your  former auditors on any matter of
accounting principles or practices, financ ial statement disclosure, or auditing
scope or procedure, and

- the disagreement(s), if not resolved to the satisfaction of your former auditors,
would have caused them to make reference to the disagreement(s) in their reports.

 In the event of  a disagreement and/or  reportable event, It em 304(a)(1 )(iv) of
Regulation S-B specifies additional disclosures.

3. Please amend your report to include a ll of the information required by Item
304(a)(2) of Regulation S-B, concerning the engagement of the new accountant.  State
whether, during your two most recent fiscal years and any subsequent interim period, the new accountant was consulted about the items in each of subparagr aphs (i) and (ii).

4. Your Commission File Number for 1934 Act filings was changed to 1-31885 when you filed Form 8-A on November 3, 2003.  Please use this number for future filings.

Mr. Andrew Makrides
Bovie Medical Corporation
May 2, 2007
Page 3

 Please file your response and amendm ent via EDGAR in response to these
comments within 5 business days after the date  of this letter.  Please contact the staff
immediately if you require longer th an 5 business days to respond.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing review ed by the staff to be certain that they have provided all
information investors require for an inform ed decision.  Since the registrant and its
management are in possession of all facts rela ting to a registrant’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in writing, a
statement from the registrant acknowledging that:
• the registrant is responsible for the adequacy and accuracy of the
disclosure in the filing;
• staff comments or changes to disclosu re in response to staff comments
do not foreclose the Commission from taking any action with respect to
the filing; and
• the registrant may not assert st aff comments as a defense in any
proceeding initiated by the Commissi on or any person under the federal
securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 If you have any questions, please call me  at (202) 551-3606.  In my absence, you
may call Brian Cascio, Branch Chief at (202) 551-3676.

       S i n c e r e l y ,

       J e a n n e  B e n n e t t
       S t a f f  A c c o u n t a n t

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 6010

August 30, 2005

Andrew Makrides
President, Chief Executive Officer
Bovie Medical Corporation
734 Walt Whitman Road
Melville, New York 11747

Re:	Bovie Medical Corporation
	Amendment No. 5 to Registration Statement on Form S-3
	Filed August 25, 2005
	And Documents Incorporated by Reference
	File No. 333-120741

Dear Mr. Makrides:

      We have reviewed your revised filings and have the following
comments.  Where indicated, we think you should revise your
documents
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Amendment No. 5 to Registration Statement on Form S-3

1. We note the change to the signature page regarding your CFO.
Please tell us whether you have experienced any reportable events
under Item 5.02(b) or (c) of Form 8-K.

2. Tell us the facts surrounding the resignation of your CFO.

Part II

Signatures

3. Revise to clarify who is signing your registration statement in
the capacity of Chief Accounting Officer or Controller.

* * *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Traci Hornfeck at (202) 551-3642, or Brian
Cascio, Branch Chief, at (202) 551-3676, if you have questions
regarding comments on the financial statements and related
matters.
Please contact Tim Buchmiller at (202) 551-3635 or me at (202)
551-
3617 with any other questions.
							Sincerely,

							Russell Mancuso
							Branch Chief

cc:	Alfred V. Greco, Esq. (via fax)
??

??

??

??

Andrew Makrides
Bovie Medical Corporation
August 30, 2005
Page 2

</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 6010

July 22, 2005

Andrew Makrides
President, Chief Executive Officer
Bovie Medical Corporation
734 Walt Whitman Road
Melville, New York 11747

Re:	Bovie Medical Corporation
	Amendment No. 3 to Registration Statement on Form S-3
	Filed July 15, 2005
	And Documents Incorporated by Reference
	File No. 333-120741

Dear Mr. Makrides:

      We have reviewed your revised filings and have the following
comments.  Where indicated, we think you should revise your
documents
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Amendment No. 3 to Registration Statement on Form S-3

Risk Factors, page 6

1. We note your response to comment 1.  Please demonstrate that
deleted disclosure was not material, considering both quantitative
and qualitative factors.  If you do not know the identity of your
ultimate customers, it is unclear why investors should not know of
the risks created by that lack of knowledge.

Where You Can Find More Information, page 29

2. You should incorporate all required reports during the
applicable
period, not just the latest amendments to those reports.

Exhibit 5.1

3. Tell us the reasons for the changes from the version of the
opinion that you filed with the previous amendment.

4. Counsel must also revise its opinion to specifically consent to
the filing of the opinion as an exhibit to the registration
statement.

Amendment No. 1 to Annual Report on Form 10-KSB for the year ended
December 31, 2004

Item 6 - Management`s Discussion and Analysis

Results of Operations

5. We note the revisions you have made in response to comment 19
in
our letter dated May 12, 2005.  Please continue your efforts to
further explain the reasons for the material variations in your
operating results during the periods discussed.  For example, we
note
you have indicated that your sales to Arthrex increased by $2.4
million for fiscal 2004 as compared to fiscal 2003 but you have
not
fully indicated the reasons why your sales to Arthrex increased by
this amount.

Item 8A - Disclosure Controls and Procedures

6. We note that the scope of your conclusion as to the
effectiveness
of your disclosure controls and procedures is still limited by
your
statement that your disclosure controls and procedures are
effective
"to bring to the attention of the Company`s management the
relevant
information necessary to permit an assessment of the need to
disclose
material developments and risks pertaining to the Company`s
business
in its periodic filings with the Securities and Exchange
Commission."
Since the conclusion as to the effectiveness of the disclosure
controls and procedures only addresses a subset of the elements of
the term "disclosure controls and procedures" as set forth in
Exchange Act Rule 13a-15(e), please either expand your conclusion
to
address all of the material elements of that term or,
alternatively,
to the extent that the conclusion would be true, please remove the
limitation on the scope of the conclusion (for example, by
removing
all of the words that appear after the word "effective").

Item 10 - Executive Compensation

7. We note the employment agreements that you have filed as
exhibits
to your Form 10-KSB/A and your disclosure that "[i]n January 3,
2004,
we extended employment contracts with certain of its officers for
two
years."  Please tell us whether any written amendments to the
employment agreements you have filed have been entered into.  If
written amendments do exist, they should also be filed as
exhibits.

8. We note the first footnote to the table on page 22 that
summarizes
the basic terms of the employment agreements.  Please tell us how
you
determined to include total extensions for six years for purposes
of
indicating the expiration dates of the related employment
agreements.
Also, it appears that the employment agreements identified in the
table may be terminated by the employee at any time upon at least
thirty (30) days prior written notice to your company.  As
applicable, please disclose the terms upon which the employees may
terminate the employment agreements identified in the table.

9. We note the provisions contained in Sections 10(d) of the
agreements with each of Messrs. Makrides, Saron and Citronowicz
and
Section 10 (c) of the agreement with Mr. Peabody.  Please revise
your
disclosure to describe the termination and change-in-control
arrangements as required by Item 402(g)(2) of Regulation S-B.

Exhibits

10. Your response to comment 8 indicates that that the Emergency
Medical Innovations agreement may be material; therefore, it
should
be filed.

* * *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Traci Hornfeck at (202) 551-3642, or Brian
Cascio, Branch Chief, at (202) 551-3676, if you have questions
regarding comments on the financial statements and related
matters.
Please contact Tim Buchmiller at (202) 551-3635 or me at (202)
551-
3617 with any other questions.
							Sincerely,

							Russell Mancuso
							Branch Chief

cc:	Alfred V. Greco, Esq. (via fax)
??

??

??

??

Andrew Makrides
Bovie Medical Corporation
July 22, 2005
Page 4

</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

FORM 3-CLARIFCATION TO COMMENT#16

U.S.
Securities and Exchange Commission

Division
of Corporation Finance Section of Filings and Reports

450 Fifth
Street, NW

Washington
DC 20549

Attn: Tim
Buchmiller: Mail Stop 6010

Re: Bovie
Medical Corporation Amendment No. W File No. 333-120741

Registration
Statement on Form S-3 - Clarification to Comment #16

Sir:

In
reference to your comment #16, we would like to clarify our response as to why

Bovie
management believes that the fair value of the indefinite life intangible asset,
brand

name/trade
mark acquired when we (fka-An-Con Genetics, Inc.) purchased the Bovie

Corporation
was $1,877,299.

In 1998,
we issued 3,000,000 shares valued at $1.00 per share to Maxxum Corporation

in
exchange for certain assets of the Bovie Business which included inventory and

equipment
to produce electrosurgical generators and the brand name/trademark of Bovie.

The
transaction was accounted for as a purchase. Management valued the inventory and

equipment
at $1,122,701 and the brand name/trademark at $1,877,299.

Bovie is
and has been a highly recognized brand name in the medical generator

industry
since electrosurgery was first practiced in 1924 by the famed Harvard physicist

William
Bovie. For decades, surgeons and other operating room personnel have called

the
electrosurgical generators they use “Bovie’s” even if they are manufactured by

another
company. The Bovie name has become generic and synonymous with

electrosurgical
generators in the medical industry. We purchased this brand

name/trademark
with the intention of using and promoting it. It is our belief that without

the use
of the Bovie name/trade mark, we would not have been able to enter the

electrosurgical
market and grow as we have over the past few years nor would we have

been able
to compete in the electrosurgical generator market.

The
reason we believe the trade name Bovie has an indefinite life is because it has

been used
continuously for the past 80 years and it allows our sales representatives easy

access to
talk to prospective customers that know the name Bovie that might not know

the name
An-Con/Aaron as being associated with electrosurgical products.

In June
201, the Financial Accounting Standards Board (“FASB”) issued statement of

Financial
Accounting Standards No 141, “Business Combinations” and No. 142.

“Goodwill
and Other Intangible Assets” effective for fiscal years beginning after

December
31, 2001. Under the new rules, goodwill and intangible assets deemed to have

indefinite
lives were no longer amortized, but were subject to periodic impairment tests in

accordance
with the statements. Other intangible assets continued to be amortized over

their
useful lives. The statement also required business combinations initiated after
June

30, 2001
to be accounted for using the purchase method of accounting, and establishes

new
criteria for recording intangible assets separate from goodwill. Pursuant to the

adoption
of SFAS No. 142, all amortization expense on intangible assets with indefinite

lives
ceased on January 1, 2002. We have performed the required impairment tests of

brand
name/trade mark. There was no reduction in the cost of the brand name/trademark

based on
that recent test.

Respectfully,

/s/

Chuck
Peabody

Controller

July 20,
2005

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 03-06

May 12, 2005

Andrew Makrides
President, Chief Executive Officer
Bovie Medical Corporation
734 Walt Whitman Road
Melville, New York 11747

Re:	Bovie Medical Corporation
	Amendment No. 2 to Registration Statement on Form S-3
	Filed April 28, 2005
	And Documents Incorporated by Reference
	File No. 333-120741

Dear Mr. Makrides:

      We have reviewed your revised filings and have the following
comments.  Where indicated, we think you should revise your
documents
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Amendment No. 2 to Registration Statement on Form S-3

Risk Factors - Page 3

We distribute a significant amount of our products - Page 4

1. Since the region remains sufficiently significant to you as to
be
named in your risk factors, we reissue the second sentence of
comment
5.

If we are unable to protect our proprietary... - Page 7

2. We note your response to our prior comment number 7.  Since
your
risk factor still describes risks associated with your ability to
protect your proprietary and intellectual property rights, please
either clarify, if true, that none of your individual patents are
material or indicate in your disclosure under "Patents and
Trademarks" on page 6 of your annual report on Form 10-K for the
fiscal year ended December 31, 2004 the duration of any material
patents that you hold.  Please also revise the disclosure under
"Patents and Trademarks" to clarify your disclosure that your
patents
are "specific, as opposed to general in nature."

3. Please revise your risk factors to clarify to your investors
the
risks associated with not having general patent protection for the
products from which you derive a material amount of revenue.

Due to the nature of our products and their use by
professionals,...
- Page 10

4. Supplementally tell us why you have deleted the disclosure
regarding the outstanding litigation in Michigan.

Selling Stockholders - Page 16

5. We see the statements you have made in footnote 4 in response
to
comment 11 from our letter dated March 4, 2005, however, it
appears
that you have not made the required statements with respect to
John
Borer, the principal of R+R Opportunity Fund, LLP, whom you
identified in your letter dated February 14, 2005 as an affiliate
of
a broker-dealer.  Please note that if you are unable to make these
statements in your prospectus with respect to all affiliates of
broker-dealers, you must amend your registration statement before
effectiveness to be on a Form for which you are eligible to make a
primary offering, and the prospectus must state that each
applicable
seller is an underwriter.

Where you can find more information - Page 20

6. We note that you have incorporated by reference current reports
on
Form 8-K that were filed prior to the end of the fiscal year
covered
by your annual report on Form 10-K for the fiscal year ended
December
31, 2004.  Please revise so that the list of the documents you
incorporate by reference is in accordance with Item 12(a)(2) of
Form
S-3.

Exhibits

7. Please note that you must resolve all of the outstanding
comments
that were issued to you by letter dated March 2, 2005 regarding
your
application for confidential treatment for portions of Exhibit
99.1
before you request acceleration of your registration statement.

Annual Report on Form 10-KSB for the year ended December 31, 2004

Item 1 - Description of Business - Page 1

New Products - Page 2

8. We note that your response to our prior comment number 17
addresses your agreement with Jump Agentur.  Our prior comment
number
17, however, inquired about your agreement with Emergency Medical
Innovations LLC.  Please provide a response to our prior comment
number 17 that addresses the inquiries made in that comment with
respect to Emergency Medical Innovations LLC.

Item 6 - Management`s Discussion and Analysis - Page 7

Results of Operations - Page 9

9. We reissue our prior comment 19.  Please expand your discussion
to
indicate the reasons for the material variations in the sales of
your
product categories over the periods presented.  As one example,
please describe the reasons for the significant increase in sales
of
your electrosurgical products to Arthrex and clarify in your MD&A
discussion when you are referring to Arthrex and when you are
referring to OEMs in general.

Item 8A - Disclosure Controls and Procedures - Page 16

10. We note your statement that your disclosure controls and
procedures are effective "to bring to the attention of the
Company`s
management the relevant information necessary to permit an
assessment
of the need to disclose material developments and risks pertaining
to
the Company`s business in its periodic filings with the Securities
and Exchange Commission."  If you wish include such language
explaining the scope of the conclusion, please ensure that it is
substantially similar in all material respects to the language
that
appears in the entire two-sentence definition of "disclosure
controls
and procedures" set forth in Rule 13a-15(e).  Please revise your
filing accordingly.

Item 11 - Security Ownership of Certain Beneficial Owners and
Related
Transactions - Page 21

11. We note your response to our prior comment number 23, however,
it
appears that you have not made the calculation of beneficial
ownership as directed in Instruction 3 to Item 403 of Regulation
S-B.
As requested by our prior comment number 23, please revise the
table
or demonstrate supplementally that the corrected calculations
would
not result in any material changes.

Financial Statements

Consolidated Statement of Operations - Page F-4

12. We note on page F-8 that you received insurance proceeds for
hurricane damage of $297,000 in 2004 and have classified this
transaction as extraordinary income on the statement of
operations.
However, we note that paragraph 5 of APB 30 states that "an
extraordinary item is an event or transaction that should be both
unusual in nature and infrequent in occurrence when considered in
relation to the environment in which the entity operates."  In
that
regard, we note that the facility damaged is located in St.
Petersburg, Florida, where hurricanes are not unusual or
infrequent.
Please revise to present the gain on insurance proceeds as
operating
income as required by paragraph 45 of SFAS 144 or tell us why you
believe your classification as extraordinary income is
appropriate.

13. In addition, on page 12 we note that the net costs allocated
to
the damaged building were $52,000.  Please tell us and revise to
disclose how you determined the cost allocated to the portion of
the
building damaged by the hurricane.

Note 2.  Description of Business - Page F-16

14. We note your response to prior comment 37 and continue to
believe
that the joint venture is a variable interest entity, as defined
in
FIN 46(R).  It appears as though the equity investment at risk is
not
sufficient to support the operations of the entity without
additional
subordinated financial support since you are funding all of their
operations.  Additionally, it does not appear that JUMP, a holder
of
the equity investment at risk, absorbs the expected losses of the
entity.  If you disagree, tell us why you believe that the joint
venture is not a variable interest entity and in your response
specifically address the factors in paragraph 5 (a-c) of FIN
46(R).

15. As a related matter, if you determine that the joint venture
is a
variable interest entity, please provide us with your analysis of
whether Bovie is the primary beneficiary of the joint venture.  We
reference the joint venture agreement which states that "any
additional capital required is the sole responsibility of Bovie."
Please reconcile this with your response 37(d) which indicates
that
you have no guarantees or subordinated financial support. If you
will
not provide or guarantee the additional capital required by the
joint
venture clarify the expected source of this capital. In addition,
your response seems to indicate that there is no difference
between
your current accounting and the accounting treatment if you were
to
consolidate the joint venture. However, your accounting policies
indicate that this joint venture is accounted for under the equity
method. Please revise to clarify. Refer to paragraphs 14 and 15 of
FIN 46 (R) in your response.

Note 6. Intangible Assets- Page F-18

16. We reference your response to comment number 33. Please
clarify
the reference to goodwill in the response since we note no
goodwill
recorded in the financial statements. Please tell us details of
how
the tradename was valued and how the useful life was determined.
Your
response only refers to an independent appraisal done on goodwill.
The footnote should also be revised in future filings to correct
the
goodwill reference.

Note 12.  Commitments and Contingencies - Page F-23

17. We note your response to prior comment 38.  We may have
further
comments on prior comment 38 based on your response to comment 37,
as
discussed above.

Deferred Revenue

18. Supplementally and in future filings clarify how you
determined
the fair value of the undelivered element (i.e. replacement of
hand
pieces) of the revenue arrangement as required by EITF 00-21.

Exhibits

19. Please file the employment agreements mentioned on page 22.

* * *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Traci Hornfeck at (202) 824-5565, or Brian
Cascio, Branch Chief, at (202) 942-1791, if you have questions
regarding our comments on the financial statements and related
matters.  Please contact Tim Buchmiller at (202) 824-5354 or me at
(202) 824-5697 with questions regarding our comments on any other
part of your filing.

							Sincerely,

							Russell Mancuso
							Branch Chief

cc:	Alfred V. Greco, Esq. (via fax)
??

??

??

??

Andrew Makrides
Bovie Medical Corporation
May 12, 2005
Page 6

</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 03-06

March 4, 2005

Andrew Makrides
President, Chief Executive Officer
Bovie Medical Corporation
734 Walt Whitman Road
Melville, New York 11747

Re:	Bovie Medical Corporation
	Amendment No. 1 to Registration Statement on Form S-3
	Filed February 15, 2005
	And Documents Incorporated by Reference
	File No. 333-120741

Dear Mr. Makrides:

      We have reviewed your revised filings and have the following
comments.  Where indicated, we think you should revise your
documents
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Amendment No. 1 to Registration Statement on Form S-3

General

1. Update your prospectus with material developments since the end
of
your third quarter, including known, material financial results
for
the forth quarter and full year.  If there are no material
changes,
please provide a supplemental representation to that effect.
Consideration should also be given to the updating requirements of
Item 310(g) of Regulation S-B.

Prospectus

2. Only a one-page cover may precede your prospectus cover.
Although
we do not object to the placement of the table of contents, other
disclosure preceding the summary should be relocated.

Cover Page of Prospectus

3. We note that you have included the last reported sale price of
your common stock on November 19, 2004.  Please update the last
reported sale price of your shares of common stock to a more
recent
date.

Risk Factors - Page 4

4. We note the revisions you have made to the second sentence of
you
introductory paragraph to your "Risk Factors" section.  Since
presumably registrants can only describe material risks that are
known to them, it is not clear why your disclosure is qualified by
reference to other risks of which you are not aware.  Please
revise.

We distribute a significant amount of our products - Page 4

5. Please expand your disclosure in response to comment 8 to be
more
specific.  For example, where in the "Middle East" do you have
distributors?  Where in "South America" do you operate that is
subject to the noted instability?  What trade protection measures
and
licensing requirements in "Asia" affect you?  What changes in the
tax
law are at issue?

6. We note your disclosure in the third paragraph that
"international
sales aggregated approximately $2.4M."  Please indicate the period
in
which you derived these sales.

If we are unable to protect our proprietary - Page 7

7. Please reconcile the disclosure in this risk factor with the
disclosure in your10-KSB in response to comment 19.  If your
patents
are immaterial, please clarify the risk to your unprotected
material
intellectual property.

Where you can find more information - Page 9

8. We reissue the portion of our prior comment number 6 that
indicated that Item 12 of Form S-3 does not permit incorporation
by
reference of a previously filed proxy statement.  Please revise
accordingly.

9. Please revise so that it is clear that the documents you have
incorporated by reference into your prospectus include your annual
and quarterly reports as amended to date.

10. Please tell us why you have not included your current report
on
Form 8-K filed on December 30, 2004 in your list of filings that
you
are incorporating by reference into your registration statement.
Please refer to Item 12(a)(2) of Form S-3.

Selling Stockholders - Page 10

11. We note from your response to our prior comment number 11 that
three of the selling stockholders are affiliated with broker-
dealers.
As such, and with respect to each such selling stockholder, please
revise your prospectus to state, if true, that:

* such seller purchased their respective shares in the ordinary
course of business; and

* at the time of such seller`s purchase of the securities being
registered for resale, such seller had no agreements or
understandings, directly or indirectly, with any person to
distribute
the securities.

Please note that if you are unable to make these statements in
your
prospectus you must amend your registration statement before
effectiveness to be on a Form for which you are eligible to make a
primary offering, and the prospectus must state that each
applicable
seller is an underwriter.

Signatures

12. Ensure that the registrant`s signature is currently dated.

Exhibit 5

13. Counsel also must consent to being named in the prospectus.

Exhibit 23

14. Revise to provide an updated accountants` consent with any
amendment to the filing.  We note that the consent is dated in
March
25, 2004.  Additionally, we note that the consent refers to "our
report dated March 25, 2004," please update the consent to reflect
the dual dated report included in the 10-KSB/A.

Amended Annual Report on Form 10-KSB/A for the year ended December
31, 2003

Item 1 - Description of Business - Page 1

15. Expand your response to comment 15 to address whether your
financial commitments under the agreement are material given your
current resources.

16. We note that you have filed the Manufacturing and Development
Agreement between you and Arthrex as Exhibit 99.1 to your
registration statement on Form S-3.  Please tell us why this
agreement should not be listed in your exhibit index as a material
contract pursuant to Item 601(b)(10) of Regulation S-B in your
annual
report on Form 10-KSB/A.  In addition, please provide a brief
description of the material terms of your agreement/relationship
with
Arthrex in "Item 1 - Business Description" of your Form 10-KSB/A.

New Products - Page 3

17. Please expand your response to comment 17 to clarify why you
have
highlighted an agreement in your annual report that you
supplementally represent is immaterial.  Also tell us the amount
you
will need to commit to bring the related product to market and why
that amount is immaterial to you.

Item 6 - Management`s Discussion and Analysis - Page 8

Results of Operations - Page 8

18. We refer to our prior comment number 22.  Please clarify
whether
any of the particular products in your cauteries and
electrosurgical
product categories have accounted for a material portion of your
product sales within each of these categories.

19. Please expand your discussion to indicate the reasons for the
material variations in the sales of your product categories over
the
periods presented.  As one example, please describe the reasons
for
the significant increase in sales of your electrosurgical products
to
the OEM customer which accounted for $3.6 million of your sales in
2003.  Please clarify, if true, that this OEM customer was
Arthrex.

20. We note that your sales to the OEM customer accounted for more
than 10% of your sales and a significant portion of your growth.
As
such, please expand your disclosure in "Item 1. Description of
Business" to briefly describe your dependence on one or a few
major
customers in accordance with Item 101(b)(6) of Regulation S-B.

Item 9 - Directors, Executive Officers, Promoters and Control
Persons
- Page 15

21. We reissue comments 26 and 27.  Please provide all required
disclosure for this item in this section.  Ensure to use all
proper
captions; see Item 405(a)(1) of Regulation S-B.

Item 10 - Remuneration - Page 17

22. We note that you have revised to remove the compensation
disclosures for Mr. Kozloff and Mr. Sablowski, and that you have
not
provided compensation disclosure for Mr. Peabody, your Chief
Financial Officer.  Supplementally describe how your disclosures
provide the required information with respect to each of these
persons covered by Item 402(a)(2) of Regulation S-B.  If your
compensation tables do not provide all of the required
disclosures,
please revise.

Item 11 - Security Ownership of Certain Beneficial Owners and
Related
Transactions - Page 21

23. Beneficial ownership must be calculated as directed in
Instruction 3 to Regulation S-B Item 403.  Securities that are not
outstanding are not included in the calculation of an individual`s
percentage ownership unless that individual has the right to
acquire
those securities within 60 days.  However, footnote (i) to your
table
indicates that you have included all shares that may be acquired
by
all of the named individuals in each individual`s ownership
calculation.  Please revise the table or demonstrate
supplementally
that the corrected calculations would not result in any material
changes.

24. We note your response to our prior comment number 30.  Please
advise us when you have completed posting your Forms 3, 4 and 5 on
your website or the date on which you intend to do so.

Item 13 - Exhibits and Reports on Form 8-K - Page 22

25. We reissue our prior comment number 31 to the extent that it
requested that you include an exhibit index listing all of the
required exhibits and indicating whether those exhibits have been
filed along with your Form 10-KSB or whether they have been
incorporated by reference.  Please refer to Item 13 of Form 10-
KSB.

Item 14 - Disclosure Controls and Procedures - Page 22

26. We reissue comment 32.  Rather than clearly stating
conclusions
as of the end of the period covered by the report, your disclosure
continues to state that Bovie carried out an evaluation "[w]ithin
90
days prior to the date of this report (`Evaluation Date`)."

27. We note your statement that your disclosure controls and
procedures were "effective at ensuring that required information
will
be disclosed on a timely basis in our periodic reports filed under
and pursuant to the Exchange Act."  If you wish include such
language
explaining the scope of the conclusion, please ensure that it is
substantially similar in all material respects to the language
that
appears in the entire two-sentence definition of "disclosure
controls
and procedures" set forth in Rule 13a-15(e).  Please revise your
filings accordingly.

Report of Independent Registered Public Accounting Firm

28. We note that in the original 10-KSB filed on March 30, 2004,
the
"Independent Auditors` Report" was dated March 30, 2004, however
in
the updated 10-KSB/A filed on February 16, 2005 the report was
dated
March 25, 2004.  Please tell us what caused the change in the
date.

Financial Statements

Consolidated Statement of Cash Flows - Page F-6

29. In future filings revise the total in the 2002 operating
activities column to indicate this is cash used by operations.

Note 1. Significant Accounting Policies

Accounts Receivable - Page F-9

30. Refer to your prior comment 37.  In future filings please
describe the nature of the sales volume discounts that you provide
to
customers and clarify the accounting treatment for these and any
other sales incentives.

Inventories and Repair Parts - Page F-10

31. Refer to your prior comments 36 and 38.  Additionally, please
clarify in future filings that the amount charged to operations
for
the obsolete raw material discussed on page F-10 represents the
write-off of the reserve.

Notes Payable - Page F-11

32. We see your proposed changes in response to prior comments 34
and
35.  Please tell us the nature of the insurance premium financing
arrangement.

Goodwill and Other Intangible Assets - Page F-11

33. We see your proposed changes in response to prior comment 40.
Please provide details of the basis for classifying the trade name
as
an indefinite-lived intangible asset.

Revenue Recognition - Page F-12

34. In future filings clearly indicate whether there are any post
shipment.

Research and Development Costs for Others - Page F-13

35. Refer to your response to prior comment 43.  We note that you
have included enhanced disclosure regarding your development
agreements; however supplementally and in future filings provide
details of your revenue recognition policy for research and
development performed for others.

Restatement of Financial Statements - Page F-17

36. In future filings when previously issued financial statements
are
revised please clearly label all the financial statements as
restated
and provide all the disclosures required by APB 20. The impact of
the
restatement should be clearly disclosed.

Note 2. Joint Venture Agreement - Page F-18

37. We see your proposed change in response 45.  We note in your
response that you indicate items, such as you own 50% of the
equity
and profits, and that the joint venture partner has contributed
little, if anything at all, etc., therefore suggesting to us that
the
joint venture could be a variable interest entity.  Please provide
us
with your analysis of why you believe that this joint venture does
not meet the requirements to be consolidated under FIN 46.

Note 12. Commitments and Contingencies - Page F-26

38. We note your response to prior comment 53 and continue to
believe
that you need to disclose as a commitment, the future financing
related to the joint venture of $1.5M.  Please revise in future
filings to disclose details of this and any other significant
commitments, contingencies or guarantees with joint ventures or
from
any other collaborative arrangements.

Note 14. Industry Segment Reporting - Page F-28

39. Refer to prior comment 56a.  Please clarify whether or not you
are licensing or selling your manufacturing rights and customer
list.
Tell us whether you have significant continuing involvement and
what
consideration you gave to the requirements of paragraph 42 of SFAS
144 when considering whether to report this as a discontinued
operation.

40. In that regard, tell us how you initially accounted and
classified the $500k related to the sale of the non-medical
product
line.  For instance did you initially record this $500k as revenue
and present it within the gain of discontinued operations?
Supplementally, tell us how you account for the $8k you receive on
a
monthly basis.

Quarterly Report on Form 10-QSB for the Period Ended September 30,
2004

41. Please expand your response to comment 61 to clarify how
location
of the end user affects commissions that you were previously
paying.
It remains unclear whether payments were paid incorrectly before
this
data became available.

Current Report on Form 8-K filed October 4, 2004

42. Tell us why the information in this filing was not disclosed
under Item 5.02 of Form 8-K.  Also demonstrate why you believe
this
filing was timely or why you believe you have satisfied the
eligibility requirements in General Instruction I.A.3(b) of Form
S-3.

Current Report on Form 8-K filed December 30, 2004

43. File the Distribution and Service Center Agreement that you
have
entered into with Symbol Medical Limited.  In addition, please
ensure
that the "Risk Factors" included in your registration statement
include any material risks that agreement may present to your
business.  For example, we note that going forward it appears that
Symbol will be your exclusive distributor and marketer in the Far
East after the terms of your agreements with your existing
distributors expire.

* * *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      December 22, 2004

Andrew Makrides
President, Chief Executive Officer
Bovie Medical Corporation
734 Walt Whitman Road
Melville, New York 11747

Re:	Bovie Medical Corporation
	Registration Statement on Form S-3 filed November 23, 2004
	Registration No. 333-120741

Dear Mr. Makrides:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Registration Statement on Form S-3

General

1. We note that the certifications filed as Exhibits 31.1 and 31.2
to
your Form 10-KSB and Forms 10-QSB that have been incorporated into
your registration statement were not in the proper form.  The
required certifications must be in the exact form prescribed and
the
wording of the required certifications may not be changed in any
respect.  For example, we note that paragraph 4 of Exhibits 31.1
does
not follow the form prescribed by Item 601(b)(31) of Regulation S-
B.
Accordingly, please file an amendment to each of your latest Form
10-
KSB and subsequent Forms 10-QSB that includes the entire report
together with the certifications of each of your CEO and CFO in
the
form currently set forth in Item 601(b)(31) of Regulation S-B.

2. Consideration should be given to the updating requirements of
Item
310(g) of Regulation S-B.
3. A currently dated consent of the independent auditors should be
included in the amendment that will be declared effective.  In
addition, the date of the audit report of March 25, 2003
referenced
in the consent does not agree with the date of the report included
in
the 10-KSB of March 30, 2004.  Please revise.

Where you can find more information - Pages 3 to 4

4. Please reorganize your prospectus so that this section appears
after your "Summary" and "Risk Factors" sections.

5. Please include the name of a contact person at Bovie Medical
and
the statement required by Item 12(c)(1)(i) of Form S-3.

6. Item 12 of Form S-3 does not permit incorporation by reference
of
a previously filed Schedule 13D or proxy statement.  Also, Item
12(a)(3) requires that you incorporate your Exchange Act
registration
statement.  Please revise accordingly.

Risk Factors - Pages 6 to 14

7. Please revise the second and third italicized sentences of your
introduction to this section to clarify that you have included all
material risk factors.  Revise your risk factors as necessary to
include a discussion of all material risks.

	We conduct a significant amount of our sales - Pages 6 to 7

8. Disclose where you have material international sales and
operations.  Also clarify how the generic risks in the bullet list
apply to those countries.

	If we fail to attract, here and retain qualified and key
personnel - Page 11

9. Please revise the last paragraph of this risk factor to clarify
what you mean by "potential taxes."

Selling Stockholders - Pages 16 to 18

10. For each selling stockholder that is a nonpublic entity,
please
identify the natural person(s) with voting or investment control
over
the shares held by such entity.  Refer to Interpretation I.60 of
Telephone Interpretation Manual (July 1997) and Interpretation 4S
of
Regulation S-K section of 3/99 Supplement to Manual.

11. Tell us whether any selling stockholder is a broker-dealer or
affiliate of a broker-dealer.

Proceeds - Page 19

12. Please clarify under what circumstances you will be reimbursed
by
the selling stockholders.

Exhibits

13. Please file a legal opinion with your next amendment.

14. We note your application for confidential treatment.  We will
provide any comments on your application separately.  Any comments
on
your application must be resolved before you request for
acceleration
of the effective date of this registration statement.

Annual Report on Form 10-KSB for the year ended December 31, 2003

Item 1 - Business

	Jump Unipolar Low Temperature Focused Plasma Technology

15. Please direct us to where you have filed the Joint Venture
Agreement with Jump Agentur Fuer Elektrotechnik GMBH as an exhibit
to
your SEC filings.  If you have not filed such agreement as an
exhibit
to your SEC filings, please provide us with your analysis as to
why
that agreement does not need to be filed as a material agreement
as
required by Item 601(b)(10) of Regulation S-B.

16. With a view toward disclosure, please tell us the percentage
you
hold of the ownership interest in the joint venture formed with
Jump
Agentur Fuer Elektrotechnik GMBH, whether this joint venture has
recognized any revenues, and how profits are allocated among the
venture partners.

	New Products

17. Please direct us to where you have filed the exclusive
worldwide
license agreement with Emergency Medical Innovations, LLC as an
exhibit to your SEC filings.  If you have not filed such agreement
as
an exhibit to your SEC filings, please provide us with your
analysis
as to why that agreement does not need to be filed as a material
agreement as required by Item 601(b)(10) of Regulation S-B.

	Competition

18. Please expand your disclosure to describe your competitive
position in your industry and the methods by which you compete.
Please refer to Item 101(b)(4) of Regulation S-B.

	Patents and Trademarks

19. Please indicate the duration of any material patents that you
hold.  Refer to Item 101(b)(7) of Regulation S-B.

Item 6 - Management`s Discussion and Analysis

	General

20. Please provide your critical accounting policy disclosures and
the information related to the underlying estimates and judgments
required by FR-72 and SEC Release No. 33-8350.  The critical
accounting policies discussion should supplement, not duplicate,
the
description of accounting policies that are disclosed in the notes
to
the financial statements.  While accounting policy notes in the
financial statements generally describe the method used to apply
an
accounting principle, the discussion in MD&A should present an
analysis of the uncertainties involved in applying a principle at
a
given time or the variability that is reasonably likely to result
from its application over time.  Details should also be provided
of
the specific estimates and assumptions that are used in this
policy
and how these were determined.

Results of Operations

21. Please revise your MD&A to quantify and discuss each of the
significant factors that contributed to significant changes in
revenues and the various expenses amounts in the financial
statements.  For example, you indicate that the significant
increase
in revenue relates to an increase from the sale of electrosurgery
products but do not quantify or discuss the reasons for this
increase.  In addition, you also cite an increase in professional
services but do not quantify each of the specific factors or
components that contributed to the increase.  Please revise to not
only quantify all significant changes but also include details of
why
these changes occurred.  Additionally, if there are offsetting
factors you should quantify and discuss each of the offsetting
factors.  Please apply this guidance throughout MD&A.  Before
filing
your amendment, please review Interpretative Release 33-8350
(December 19, 2003) available on our Web site at
http://www.sec.gov/rules/interp/33-8350.htm.

22. Clarify which of your medical products materially contributed
to
sales.  Also disclose the extent to which those contributions
varied
over the periods presented and the reasons for that variation.

23. Discuss why the cost of sales of your OEM generators
increased.

	Financial Condition

24. Please revise to provide more details of the following as
required by Item 303 (b) of Regulation S-B:
a) Provide details of any purchase, sale or other material
commitments for capital expenditures and the expected source of
funds
for these expenditures;
b) Provide a summary of product research and development that you
plan to pursue for the next year and the expected funds needed for
these activities;
c) Discuss any known events that could have an impact on
continuing
operations such as the sale of your non-medical segment; and
d) Clarify whether you expect to be able to satisfy your short-
term
liquidity requirements or if you will need to raise additional
funds
in the next 12 months.  All sources of internal and external
sources
of liquidity should be addressed.
25. Please revise to disclose details of significant changes in
balance sheet accounts each period in MD&A.

Item 9 - Directors, Executive Officers, Promoters and Control
Persons

26. Please provide the disclosure required by Item 401(e) and (f)
of
Regulation S-B.

27. Provide the disclosure required by Regulation S-B Items 405
and
406.

28. We note that Mr. Kozloff has not been identified as an
executive
officer of your company.  Since Mr. Kozloff has been identified as
an
executive officer under Item 10, please include the disclosures
required by Item 401 for Mr. Kozloff as well.

Item 10 - Remuneration

29. Revise your disclosure to use the table format and column
headings required by Item 402 of Regulation S-B.

Item 11 - Security Ownership of Certain Beneficial Owners and
Management of Bovie

30. Please tell us how you are complying with Exchange Act Rule
16a-
3(k).

Item 13 - Exhibits and Reports on Form 8-K

31. Please conform the heading of this Item to "Exhibits" as
required
by Form 10-KSB and furnish the exhibits required by Item 601 of
Regulation S-B.  For example, please file the agreements mentioned
in
the section entitled "Reliance on Collaborative, Manufacturing and
Selling Arrangements" of Item 6.  In addition, please include an
exhibit index listing all of the required exhibits indicating
whether
those exhibits have been filed along with your Form 10-KSB or
whether
they have been incorporated by reference.

Item 14 - Disclosure Controls and Procedures

32. Revise this filing and your most recent quarterly report to
comply with Regulation S-B Item 307 which requires the conclusions
be
stated as of the end of the period covered by the report.

Financial Statements

Consolidated Statement of Shareholders Equity
33. Tell us the difference between "Subscription receivable paid
in
cash" and "Subscription Receivable."  Also the subscription
transaction should be disclosed in the footnotes.

Consolidated Statement of Cash Flows

34. Please tell us the nature of the short term notes and where
these
are disclosed in the accounting policies.

35. Please tell us where the term loan payment and the line of
credit
payment from Note 7 are reflected in the financing activities of
the
statement of cash flows.

36. Please provide details of the inventory and parts and
development
costs write-downs included in the statement of cash flows and
indicate where these amounts have been disclosed in the footnotes.
The specific circumstances and assumptions related to these write-
downs should be clearly disclosed.  If there have been any
subsequent
sales of inventory that have been written-down the impact of
theses
sales on margins should be disclosed in MD&A.

Note 1.  Accounts Receivable
37. We reference the allowance for discounts in Note 3.  Please
include a description of the discount policy that you use in
relation
to accounts receivable and the amount that was written-off for
each
year.

Note 1.  Inventory and Repair Parts
38. Please tell us where the inventory reserves are reflected in
the
balance sheet.  In addition, the reserves and write-offs each
period
should be separately disclosed in Note 1.  Clarify whether these
reserves establish a new cost basis.
39. Please provide details of the reason that repair parts are
classified as a non-current asset.

Long-lived Assets
40. Please provide details of the basis for classifying trade name
as
an indefinite-lived intangible asset.  In addition, provide more
details about how you evaluate and test indefinite-lived
intangibles
and goodwill for impairment.

Revenue Recognition and Product Warranty

41. Please provide more details of the revenue recognition policy
for
all significant products and services and the basis for
recognition
of revenue at shipment, including details of post-shipment
obligations, customer acceptance, rights of return, etc. and how
these impact revenue recognition.  In addition, provide details of
discounts, credits and other sales incentives and clarify the
accounting treatment.
42. Please provide more details of product warranties, including
the
reconciliation of the reserve as required by FIN 45.
43. Tell us and discuss in your revised filing your revenue
recognition policy for research and development performed for
others
as noted in Note 15.

Research and Development

44. Please separately disclose the amounts of any development
costs
that are capitalized.

Note 2. Joint Venture Agreement

45. Please provide details of the ownership percentage of the
joint
venture and the related accounting treatment.  Provide details of
whether the equity investment meets the requirements of Rule 4-08
(g)
of Regulation S-X for summarized financial information.

Note 5 - Due to Shareholders

46. We reference the amounts included in the financial statements
related to the recission offer made by the Company.  Provide more
details of this offer and how this has been recorded in the
financial
statements.

Note 6.  Intangible Assets

47. Please revise to remove indefinite lived intangible assets
(trade
name and goodwill) from those that are subject to amortization. In
addition, assets that have been fully amortized should be removed
from this table.  The total in the table should also agree with
the
balance sheets.
48. Tell us why the Electrosurgery Technology, Multifunction
Cautery
and the patent rights original balances decreased or were written-
off
separate from the normal accumulated depreciation.
49. Please revise to separate the useful lives by type of
intangible
asset.

Note 8.  Options
50. Please revise the "Summary of Significant Policies" footnote
to
include the required information regarding stock-based
compensation
in paragraph 2 (c) (1-5) of SFAS 148.

51. Provide details of the 1.8 million stock options granted
during
the year, including whether the price was at fair value (and how
this
was determined) and the amount of any compensation recorded.

Note 9.  Taxes and Net Operating Loss Carryforwards
52. We note that the Company believes that it is possible that the
benefit of these assets may not be realized in the future,
therefore
tell us why the net current deferred tax assets have not changed
from
2002 to 2003, and why a valuation allowance has not been
established
for the entire deferred tax asset.

Note 12. Commitment and Contingencies

53. We reference the discussion in Item 1 that the Company is
responsible for securing an estimated $1.5 million in financing
for
the joint venture with the German company.  Disclose details of
any
significant commitments, contingencies or guarantees with this or
any
other joint venture or from any other collaborative arrangement.
54. Provide supplemental details of whether the existing policy
for
product liability insurance that expires December 31, 2004 has
been
renewed.
Note