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)
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Andrew Makrides
Bovie Medical Corporation
May 12, 2005
Page 6