June 30, 2005

By Facsimile ((212) 603-2001) and U.S. Mail

Richard S. Green, Esq.
Thelen Reid & Priest LLP
875 Third Avenue
New York, NY  10022

	Re:	Pure World, Inc.
		Schedule TO-C filed June 6, 2005
		Filed by Naturex Acquisition Corp. and Naturex S.A.

		Schedule TO-T filed June 17, 2005
		Filed by Naturex Acquisition Corp. and Naturex S.A.

Dear Mr. Green:

      We have reviewed your 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.

Schedules TO-C
1. We note the statement that Naturex disclaims any obligation to
update or revise the information contained in any "forward-looking
statement."  This disclaimer is inconsistent with the requirements
of
General Instruction F of Schedule TO and your obligations under
Rule
14d-6(c) to amend the Schedule to reflect a material change in the
information previously disclosed.  Please confirm that the bidders
will avoid using this statement in all future tender offer
materials.


Schedule TO-T

Offer to Purchase

Terms of the Tender Offer, page 8
2. We note the disclosure in the fourth paragraph of this section
that Naturex "may be deemed to beneficially own the Shares)... to
be
tendered by Koether Stockholders pursuant to the Stockholder
Agreement."  Isn`t your purchase of the "Koether Shares"
contingent
on consummation of the tender offer?  As we read the Stockholder
Agreement, that purchase will not occur unless the offer closes.
If
that is not your reading of the Agreement, please advise in your
response letter.  As you know, if Naturex is deemed to have
acquired
the Koether Shares already, this will impact the disclosure
required
under applicable federal securities laws.

Withdrawal Rights, page 13
3. The disclosure in the third paragraph in this section is
confusing
and does not appear consistent with your obligations as a bidder
under Regulation 14D.  Describe with specificity those
circumstances
under which you believe the Depositary could, consistent with our
rules, retain tendered Shares without allowing withdrawal rights
where the bidder is "delayed in its acceptance for payment of
Shares
or is unable to accept Shares for payment pursuant to the Offer."
Otherwise, delete the statement.

Certain U.S. Federal Income Tax Consequences, page 14
4. We note your disclosure that this section summarizes "certain"
of
the material federal income tax consequences of the tender offer
and
merger.  Please ensure that you discuss all such material
consequences.  Also, delete the reference to this discussion being
for "general information only."  Security holders are entitled to
rely upon the discussion.

Certain Information Concerning the Company, page 15
5. We note the statement that none of the bidders or their
affiliates
intend to update the financial projections to reflect the
occurrence
of future events.  This disclaimer is inconsistent with the
requirements of General Instruction F of Schedule TO and your
obligations under Rule 14d-6(c) to amend the Schedule to reflect a
material change in the information previously disclosed.  Please
confirm that the bidders will avoid this statement in all future
tender offer materials.



Certain Projections Provided by the Company, page 16
6. We note that you have summarized some the financial projections
provided by Pure World to you.  Please provide us with a copy of
the
complete financial projections and tell us your basis for not
disclosing the information in its entirety.
7. Summarize the material assumptions underlying the projections
presented.

Source and Amount of Funds, page 18
8. Please disclose the current interest rate with respect to your
existing credit facilities.  With respect to your new credit
facilities, provide the terms of the facilities as required by
Item
1007(d) of Regulation M-A.

Closing Information

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing 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 investment 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 bidders acknowledging that:

* the bidders are 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 bidders 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
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      Please direct any questions to me at (202) 551-3619 or, in
my
absence, to Christina Chalk, Special Counsel, at (202) 551-3263.
You
may also contact me via facsimile at (202) 772-9203.  Please send
all
correspondence to us at the following ZIP code: 20549-3628.


					Sincerely,



					Daniel F. Duchovny
					Attorney-Advisor
					Office of Mergers & Acquisitions

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Richard S. Green, Esq.
Thelen Reid & Priest LLP
June 30, 2005
Page 1



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

         DIVISION OF
CORPORATION FINANCE