My guess would be water weight too. All of the hormonal changes we go through can account for a few pounds, but most of the time when people lose a drastic amount of weight when they first start an appetite suppresant it has more to do with carbohydrate intake.
Because phentermine makes you less hungry, you would naturally eat alot less actual food. Carbohydrates make you retain water, so when you drastically reduce the number of grams you eat in a day-whether it's intentional or not-you end up dropping water weight. You have probably consciously cut out junk food-like sweets and salty snacks. All of that stuff is loaded with carbs, and also sodium.....which is ALSO known to cause water retention.
I'm so happy for you that your weight loss is going so well!
Water weight, whatever! My doctor wanted to put me on some hormone medication and told me it usually makes people gain water weight, but that shouldn't bother me.....
I don't care what it is-I can tell myself it's water all day long and it wouldn't make my pants fit any better  With that much of a loss, I'm sure atleast SOME of it is fat. So even if that's what it is, who cares? You should notice your clothes looser. As long as you ease back into a normal healthy diet when you get off the phen, it's possible to gain very little (or even none) of it back.
If I could wake up next week 10 pounds lighter on the scale, I wouldn't give a hoot what it was or why.....I'd be too busy doin some old school cabbage patch victory dance in my bathroom 
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