She immerses 95 times (according to Beis Shamai), as follows;

The first week she immerses every night. Each day could complete seven days after Yoledes Zachar;

The second week she immerses every night (perhaps it completes 14 days after Yoledes Nekevah) and every day (perhaps she was Yoledes Zachar b'Zov, and just completed seven clean days).

The third week she immerses every day (perhaps she was Yoledes Nekevah b'Zov, and just completed seven clean days);

According to Beis Shamai, she immerses also every night (of the third week and the remainder of the 80 nights after she came, perhaps she just finished Yemei Tohar after Yoledes Nekevah). They require a Tevulas Yom Aruch (a Yoledes during Yemei Tohar) to immerse at the end of Yemei Tohar.

Question: She immerses 35 times during the first three weeks, and the 59 following nights (until 80 days are completed). This is only 94 immersions!

Answer (R. Yirmeyah mi'Difti): The case is, she arrived Bein ha'Shemashos (Safek day, Safek night. She immerses also when she arrives (but this does not count towards the 80 days, perhaps she gave birth Bein ha'Shemashos just before coming, and it was already night).

Question: Beis Hillel do not require a Tevulas Yom Aruch to immerse at the end of Yemei Tohar. What 35 immersions do they require?

Answer: They agree to the first 28 immersions mentioned above (a:1-3). Additionally, she immerses every night of the fifth week. Perhaps (what she saw a week ago was the first day after Yemei Tohar, so) she just finished the seven days of Nidah.

Question: Why does the Tana mention 10 weeks (after the first three)? All 95 immersions are within 80 days, which is only eight and a half weeks (after the first three weeks)!

Answer: Since he had to discuss part of the ninth week, he discusses the entire week. Since he must discuss the ninth week (of Tum'ah), he discusses the following clean week.

Question: Additionally, she must immerse after (every clean week. Perhaps it concludes seven clean days after) being a Zavah!

Answer: Beis Hillel count only the immersions before Bi'ah is permitted (on night 35), but not those afterwards.

Question: Beis Shamai count immersions (on nights) after night 35. Why do they omit immersions after Zivah (which are during the day)?

Answer: They discuss only immersions due to the birth.

Question: They discuss immersions due to Yoledes b'Zov!

Answer: They discuss immersions due to Yoledes b'Zov, but not for a regular Zavah.

Question: She should immerse each day of the first week during the day, perhaps it concludes seven clean days after Yoledes b'Zov!

Answer: The Tana holds like R. Akiva, who says that a Zavah does not immerse unless she definitely had seven clean days (she checked herself). Here, she did not check herself until she came.

Question: She should immerse during the last day of the first week (it concludes seven definitely clean days)!

Answer: The Tana does not count a lone immersion in a week.

Question: She should also immerse the first day during the day! Perhaps she is a Shomeres Yom k'Neged Yom. (I.e. perhaps she saw Dam Zivah yesterday.)

Answer: The Tana discusses immersions of a Zavah Gedolah (who saw three consecutive days and must bring a Korban), but not of a Zavah Katanah.

We learn three things about the Tana:

He holds like R. Akiva, that a Zavah does not immerse unless she definitely had seven clean days;

He holds like R. Shimon, who forbids Bi'ah on the seventh clean day, lest she see later that day. (This revealing that retroactively she was still a Zavah);

(He holds that Beis Hillel and Beis Shamai agree that) Tevilah bi'Zemanah Mitzvah. (It is a Mitzvah to immerse at the first possible time.)

(Beraisa - R. Yosi b'Rebbi Yehudah): It suffices for her to immerse once at the end.

He does not hold that Tevilah bi'Zemanah Mitzvah.

(Mishnah): If a woman miscarried on (or before) the 40th day (from immersion, it is at most 40 days from conception, so) there is no concern lest it was a proper child (to obligate a Korban and to cause Tum'as Yoledes);

If she miscarried on day 41 (or later), she is Safek Yoledes Zachar or Nekevah, Safek Nidah.

R. Yishmael says, if she miscarried on day 41 (or later, but before day 81), she is Safek Yoledes Zachar, Safek Nidah;

If she miscarried on day 81 (or later), she is Safek Yoledes Zachar or Nekevah, and Safek Nidah.

This is because a male is fully formed on the 41st day (40 full days after conception), and a female is fully formed on the 81st day.

Chachamim say, both males and females are fully formed on the 41st day.

(Gemara) Question: Why does the Mishnah mention that she might be Yoledes Zachar?

This does not add to her days of Tum'ah. (She is concerned for two weeks of Tum'as Yoledes Nekevah);

She does not have days of Dam Tohar! (Perhaps she is a Nidah.)

Answer: If she will see blood on days 34 and 41, she may not immerse until day 48. (Perhaps she was Yoledes Zachar, and day 41 began Nidah. Had it taught only about Yoledes Nekevah and Nidah, we would have thought that on day 41 she saw Dam Tohar or one day of Zivah (Shomeres Yom k'Neged Yom), and either way she may immerse on day 42 and have Bi'ah the next night.)

Likewise, if she will see blood on days 74 and 81, she may not immerse until day 88. (Perhaps she was Yoledes Nekevah, and day 81 began Nidah.)

(Mishnah - R. Yishmael): If she miscarried on day 41 she is Yoledes Zachar or Nidah.

(Beraisa - R. Yishmael): The Torah gave days of Tum'ah and Taharah for giving birth to males and females;

Just like the combined days of Tum'ah and Taharah for a male (40) equal the days of its formation, also regarding females they are the same (80).

Chachamim: We do not learn formation of a fetus from Tum'ah.

Chachamim: An experiment was done with two female slaves sentenced to death by Cleopatra. They were allowed to have Bi'ah with their husbands only on one night. They were killed 41 days later. They cut open their wombs, and found a male in one and a female in the other.

R. Yishmael: I bring a proof from Torah, and you bring a proof from fools?!

Question: What was his proof from Torah?

If he learns from the days of Tum'ah and Taharah, Chachamim said, we do not learn the formation of the fetus from Tum'ah!

Answer: It says "Teled" regarding a female, to teach that a female requires an extra period of formation.

Question: Why did he call Chachamim's proof "a proof from fools"?

Answer: Perhaps the female was conceived 40 days before the known night of Bi'ah.

Chachamim say, a potion was used to cause any previous fetus or semen to leave the womb.

R. Yishmael says, potions do not work on everyone.

R. Yishmael: An experiment was done with two slaves sentenced to death by Cleopatra. They were only allowed to have Bi'ah on one night. One was killed 41 days later, and they found a male inside. The other was killed 81 days later, and a female was inside.

Chachamim: We do not bring a proof from fools.

Question: Why did they call this "a proof from fools"?

Answer: Perhaps the female was conceived 40 days after the known night of Bi'ah.

R. Yishmael says, a guardian ensured that no one else had Bi'ah with her.

Chachamim say, we do not rely on a guardian. Perhaps he himself had Bi'ah with her!

Question: How does R. Yishmael bring a proof from this? Perhaps the female was already formed on day 41!

Answer (Abaye): On day 81 it was no more developed than the male was on day 41.

(Mishnah - Chachamim): Both males and females are fully formed on the 41st day.

Question: This is like the first Tana!

Answer: This was taught in the name of Chachamim to teach that it is the majority opinion. The Halachah follows it.

Question: We already know this, for the first opinion is Stam (anonymous)!

Answer: One might have thought that the Halachah follows R. Yishmael because his reasoning is better, and a verse supports him. The latter clause teaches that this is not so.

(R. Simlai): A fetus in the womb is like a folded writing tablet;

His hands are on his temples, his elbows (Tosfos; Rashi - underarms) are on his knees, his heels are on his buttocks, and his head is between his knees. His mouth is closed, and his navel is open. He eats and drinks from what his mother eats and drinks. He does not excrete, for this would kill his mother;

Once he is born, what was closed (his mouth) is opened, and what was open (his navel) is closed. Otherwise, he could not survive for a moment.

A lamp is above him. He is able to see from one end of the world to the other -- "b'Hilo Nero Alei Roshi l'Oro Elech Choshech";

This is not surprising. One can see distant places in a dream.

Those are the best days -- "Mi Yitneni ch'Yarchei Kedem ki'Yemei Eloka Yishmereni";

The days that are only Yerachim (months), but less than a year, are the days of pregnancy.

The fetus is taught the entire Torah -- "va'Yoreni... Yismach Devarai Libecha Shemor Mitzvosai v'Echyeh";

It also says "b'Sod Eloka Alei Ahali."

Question: Why do we need the second verse?

Answer: Perhaps Shlomo said the first verse about himself.

Once he is born, an angel slaps him on the mouth, and he forgets everything -- "la'Pesach Chatas Rovetz."

An oath is imposed on him before he is born;

"Li Tichra Kol Berech" on the day of death. "... Tishava Kol Lashon" at the time of birth.

Question: What oath is put on him?

Answer: "You must be a Tzadik, and not a Rasha. Even if everyone tells you that you are a Tzadik, consider yourself a Rasha;

Know that Hash-m is Tahor, His servants are Tehorim, and He gave you a Tahor Neshamah. If you guard its Taharah, fine. If not, Hash-m will take it back."

(Tana d'Vei R. Yishmael): A parable for this is a Kohen who gave Terumah to an ignoramus to guard it.. He told him "if you guard its Taharah, fine. If not, I will burn it in front of you."

(R. Elazar): He learns from "mi'Me'ei Imi Atah Gozi."

Question: What is the source that Gozi refers to an oath?

Answer: "Gazi Nizrech... " (Nezirus is similar to an oath).