CONFIDENTIAL, FOR USE OF COMMISSION ONLY

May 4, 2005


Via EDGAR, Facsimile and UPS Express

Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, DC 20549
Attn:       Nili Shah
            Mail Stop 0510


Re:      Human  Pheromone  Sciences,  Inc. Form 10-KSB for the fiscal year ended
         December 31, 2004 filed March 30, 2005 (File No. 0-23544)

Ladies and Gentlemen:

         This letter is in response to your letter dated April 22,  2005,  which
sets forth the Staff's comments  regarding the above referenced  filing of Human
Pheromone  Sciences,  Inc. (the "Company").  For your  convenience,  the Staff's
comments are  reproduced  below in bold type and are  followed by the  Company's
response.  The Company  proposes to make  additional  disclosures in response to
certain of the Staff's  comments  in the  Company's  future  filings and in such
cases  the form of the  proposed  disclosures  are  described  in the  Company's
responses.  Of course,  the  disclosure  that will actually be given in a future
filing  will be  modified  as  necessary  to reflect  the  particular  facts and
circumstances present for the reported periods.



         Set forth below are the Company's  responses to the comments  contained
in the Staff's letter:

     1. MD&A

                  We note that your accounts  receivable  balance as of December
                  31, 2004 has  increased  582% when compared to your balance as
                  of December 31, 2003, which  significantly  impacted your cash
                  flows used in operations. We further note that the net revenue
                  increased  by 76% for fiscal  year 2004 as  compared to fiscal
                  year 2003 and that your  receivable day sales  outstanding has
                  increased  to 54.6 days as of December 31, 2004 from 24.7 days
                  as of December 31, 2003. Due to the significant impact of your
                  receivables  on  your  cash  flows  used in  operations,  your
                  historical  cash flows used in operations,  and the volatility
                  of timing in collecting  accounts  receivable,  please provide
                  the following information,  at a minimum, in future filings of
                  your Form 10-KSB and Forms 10-QSB.


     The increase in our accounts receivable, which impacted our cash flows used
in  operations,  as well as the increase in net revenue and receivable day sales
outstanding is primarily a result of an increase in product  shipments to two of
our largest  customers in December  2004.  Based on  historical  patterns  these
orders would have been placed and shipped in the first quarter of 2005.

     Because  of the timing of these  shipments  to our  customers,  there was a
major  increase  in accounts  receivable  outstanding  at  December  31, 2004 as
compared with the prior year end.  This factor also resulted in the  significant
variance  in the  receivable  day sales  outstanding  on  December  31,  2004 as
compared with the year ended  December 31, 2003. In addition,  the percentage of
sales occurring in the last month of the quarter has increased from 25% of sales
in 2003 to 41% in 2004. This higher  concentration of sales in the last month of
the quarter increases the receivable days outstanding.  Since the calculation is
based on  averages,  it  overstates  the actual  days that our  receivables  are
outstanding.

     We advise  the Staff that 98% of the  accounts  receivable  outstanding  at
December 31, 2004 was fully  collected  before our annual audit began. We extend
30 day terms to our largest customers, since they represent the highest level of
credit-worthiness;  for other  customers,  especially  those  outside the United
States,  we  require  payment in  advance,  and do not make  shipments  until we
receive payment.




     o   Historical  sources of cash  (e.g.  operations,  sale of REALM  product
         lines, financing, etc.)

                  In recent years, we raised our funding through sales of equity
                  or asset  sales.  As stated in the Risk Factor  section of the
                  10-KSB,  we have not  sustained  profitable  operations  since
                  1997.  As  liquidity  circumstances  require,  we will  expand
                  discussions  of  all  sources  of  cash  resources,  including
                  historical  sources  and  future  requirements  and  potential
                  sources.

     o   Trends and uncertainties related to cash flows and liquidity.

                  For fiscal year 2004,  you stated that you expected  your 2004
                  sales  to  decline  due  to  maturing   fragrance  lines  with
                  shortening life cycles;  however,  your fiscal year 2004 sales
                  increased by 76%.  Your results of  operations  and  liquidity
                  discussion  should provide a  comprehensive  analysis of known
                  trends and  uncertainties  related to revenue,  including your
                  expectations  of the impact of maturing  product lines and new
                  operating focus of licensing your human  pheromone  patents on
                  future sales.

                  We sell our pheromones to companies  involved in the worldwide
                  fragrance  and  ancillary  consumer  products  markets.   Most
                  industry  market  studies have shown that a product life cycle
                  is typically not more that three years.  Our  expectation  was
                  based  on  that  belief  and on  historical  trends.  We  were
                  surprised by the increase in the customer orders. The apparent
                  increases in the business of our customers required additional
                  purchases  of product  by them.  In the  future,  we will make
                  every reasonable effort for a small company to better evaluate
                  the  needs  of  our  clients,   working  with  them,  to  more
                  adequately  forecast our periodic sales. In the future we will
                  provide  a   comprehensive   analysis  of  known   trends  and
                  uncertainties related to revenue, including our expectation of
                  the impact of maturing  product lines and new operating  focus
                  of licensing our human pheromone patents on future sales.


     o   Trends and uncertainties related to cash flows and liquidity.

                  Your gross profit margin  increased to 81% in fiscal year 2004
                  as  compared  to 73% in fiscal year 2003 and your S G & A as a
                  percentage  of net  revenue  decreased  to 124% in fiscal year
                  2004 as  compared  to 164% in  fiscal  year  2003.  Due to the
                  significance of the changes between periods presented,  please
                  provide a comprehensive  analysis of these significant trends.
                  For example,  provide more  specifics for why pheromone  costs
                  decreased in fiscal 2004.




                  During late 2003,  we altered  sourcing  arrangements  to work
                  directly  with the  manufacturer,  rather than going through a
                  third  party.  This  resulted in a large  reduction in cost of
                  goods and the improved  gross  margin.  Also,  profit  margins
                  increased  because  of the  increased  sales of  higher  gross
                  margin products.

                  When the SGA  relationship  is so affected  in the future,  we
                  will  provide  reasons for such  reduction  in costs,  in more
                  detail.  Since we do not  anticipate  such a major increase in
                  net revenue in the future we would not anticipate this type of
                  reduction of expense as a percentage of net revenue.  However,
                  if it recurs,  we will provide a more detailed  evaluation and
                  explanation.

     o   Detailed discussion and analysis regarding the trends and uncertainties
         surrounding the  collectibility of accounts  receivable,  including why
         your day sales outstanding significantly increased when compared to the
         prior period.

                  As discussed above, over 98% of our December 31, 2004 accounts
                  receivable  was collected  before our annual audit began.  Our
                  stringent  credit policies were discussed above. If we believe
                  there is an  increase  in  uncertainty  of  collectibility  of
                  accounts receivable, we will provide more detailed discussion.

     o   Detailed  discussion  and analysis  regarding your ability to meet your
         short-term and long-term cash requirements.  Specifically,  discuss how
         you intend to generate or obtain cash (e.g., business operations, asset
         sales,  debt issuances,  stock  issuances,  etc.) and how you intend to
         maintain your operations.

                  In future  discussions,  we will expand the description of our
                  ability   to  meet   our   short-term   and   long-term   cash
                  requirements.  If it is determined  that we need  financing to
                  maintain operations,  we will explore the options that we feel
                  are available to the Company, such as stock issuances.




     The Company acknowledges that:

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

     o   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

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


     Please acknowledge  receipt of this letter by stamping the enclosed copy of
this  letter and  returning  it in the  postage-paid  and  return-addressed  UPS
Express envelope provided.

     If you have any  questions  regarding  this response  please  contact me at
408-938-3030.

                                       Very truly yours,


                                       /s/ Gregory S. Fredrick
                                       -----------------------
                                       Gregory S. Fredrick
                                       Chief Financial Officer



cc:      William P. Horgan - Chairman and CEO