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)
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Andrew Makrides
Bovie Medical Corporation
August 30, 2005
Page 2