Mail Stop 6010
      July 14, 2005


VIA U.S. MAIL AND FACSIMILE (650) 802-2880

Gregory Lichtwardt
Chief Financial Officer
Conceptus, Inc.
1021 Howard Avenue
San Carlos, CA  94070


      Re:	Conceptus, Inc.
		Form 10-K for the year ended December 31, 2004
      Filed March 31, 2004
		File No. 000-27596

Dear Mr. Lichtwardt:


      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our 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 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.





Form 10-K for the year ended December 31, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 25

Results of Operations, page 31
1. We see from the significant customer disclosure (page 63) that
customers "C, E and F", who accounted for a combined 70% of your
revenue in 2003, each accounted for less than 10% of your revenue
in
2004. To the extent important to an understanding of your revenues
and trends therein, MD&A in future filings should address changes
in
significant customers.

Consolidated Financial Statements

Note 2.  Summary of Significant Accounting Policies, page 61

Revenue Recognition, page 65
2. We note from page 15 that you provide a training program for
the
use of the Essure product, including one on one training sessions
for
new physicians who have pre-scheduled Essure procedures.  We also
note that you are required to have a professional trainer in
attendance during a physician trainee`s initial procedures.  Tell
us
how you account for product revenues in transactions where you
have
training obligations and show us that your accounting is
appropriate
in GAAP.  Also, tell us whether revenue is allocated to training
services, and, if so, how the amount of that revenue is measured
and
recognized. Tell us how your practices consider the guidance from
EITF 00-21.  Unless insignificant, please make accounting policy
disclosure about this matter in future filings.

       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 cover letter with your response 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 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
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Kristin Lochhead at (202) 551-3664 or me at
(202) 551-3605 if you have questions.  In this regard, please do
not
hesitate to contact Brian Cascio, Accounting Branch Chief, at
(202)
551-3676 with any other questions.


      Sincerely,



      Gary Todd
      Reviewing Accountant

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Mr. Lichtwardt
Conceptus, Inc.
July 14, 2005
Page 3