SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3561

       November 1, 2007

Mr. Andrew D. Demott, Jr.
Senior Vice President, Chief Fi nancial Officer and Treasurer
Superior Uniform Group, Inc.
10055 Seminole Blvd.
Seminole, Florida 33772

  RE: Superior Uniform Group, Inc.
   Form 10-K for Fiscal Year December 31, 2006
Filed March 13, 2007
Form 10-Q for Fiscal Quarter Ended September 30, 2007
  Filed October 25, 2007
   File No. 1-5869

Dear Mr. Demott:

 We have reviewed your filings and have the following comments.  We have limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to  other portions of your docum ents.  Where indicated, we
think you should revise your disclosures in futu re filings 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 provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may or may not raise
additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 2
Form 10-K for Fiscal Year Ended December 31, 2006

Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations (MD&A), page 12

Operations, page 12

1. In light of the recurring year  over year decreases in your  net sales, please discuss
whether you expect this trend to continue  in the future and why or why not.  We
believe such additional disclo sure is necessary to an unde rstanding of the extent to
which reported financial information is indi cative of future results.  Refer to Item
303(a) of Regulation S-K and SEC Release No. 33-8350.

2. Please revise to explain in a reasonabl e amount of detail the reason(s) for the
significant reduction in your accrual for tax contingenc ies during fiscal year 2005
as such reduction had a 15% effect on reported net income.

Liquidity and Capital Resources, page 13

3. At times your discussion and analysis of financial condition, changes in financial condition and cash flows focuses only on fiscal 2006 and fiscal 2006 as compared
to fiscal 2005.  Please revise to provide  a discussion and analysis of financial
condition, changes in financial condition and cash flows for three year period
covered by the financial statements.  Th e discussion and analysis should address
material year to year changes in financ ial position and cash flows and the reasons
underlying those changes and provide information that is relevant to an understanding of your financial condition and cash flows.  Refer to Item 303(a) of
Regulation S-K and SEC Release No. 33-8350.

4. Please revise your table of  contractual cash obligati ons and commitments to
include estimated interest payments on outstanding debt obligations and amounts
to be funded to cover post-employment be nefits.  Because the table is aimed at
increasing transparency of cash flow, we believe these payments should be
included in the table.  If you choose not to include these payments, please provide
information regarding these cash requirements in a footnote to the table to the extent material.  See Section IV.A and footnote 46 to SEC Release No. 33-8350.

Critical Accounting Policies, page 15

5. Please revise your disclosure to desc ribe the material implications of uncertainties
associated with the methods, assumptions  and estimates underlying your critical
accounting measurements that have had or that you reasonably expect will have a
material impact on financial conditio n and operating performance and on the
comparability of reported information among periods.  Such disclosure should

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 3
supplement, not duplicate, the accounting policies disclosed in the notes to the
financial statements.  In preparing your revised disclosure, please identify those
accounting estimates or assumptions wher e there is a significant amount of
subjectivity involved, the estimates or assu mptions are susceptible to change, and
the impact of the estimates and assu mptions on your financial condition or
operating performance is material.  Discuss, to the extent material, such factors as
how you arrived at each estimate, how accurate the estimate/assumption has been in the past, how much the estimate/assumption has changed in the past and whether the estimate/assumption is reasonably likely to change in the future.  We
would expect you to provide quantitative as  well as qualitativ e disclosure when
quantitative information is reasonably availa ble and to provide greater insight into
the quality and variabilit y of information regardi ng financial condition and
operating performance.  The quantitative di sclosure should incl ude, to the extent
material, information about your provisions and allowances for doubtful accounts receivable, sales returns a nd excess and obsolete inventor ies, self-insurance stop
loss coverage and reserves, impairment lo sses, stock-based compensation, income
tax contingencies and pension and post re tirement benefit costs.  Also, since
critical accounting estimates and assumpti ons are based on matters that are highly
uncertain, you should analyze and disclose their specific sensitivity to change, based on other outcomes that are reasonabl y likely to occur and would have a
material effect.  For example, if reasonabl y likely changes in the long-term rate of
return used in accounting for your pension plan would have a material effect on
your financial condition or operating performance, the impact that could result
given the range of reasonably likely out comes should be disclosed and quantified.
Please refer to Item 303(a)(3)(ii) of Re gulation S-K as well as the Commission’s
Guidance Regarding Management’s Disc ussion and Analysis of Financial
Condition and Results of Operations, SEC Release No. 33-8350, issued December
19, 2003 and available on our website at
www.sec.gov .

Item 8. Financial Statements and Supplementary Data, page 18

Consolidated Statements of Earnings, page 18

6. Please revise to show a separate line ite m for material gains on sale of property,
plant and equipment.  Also disclose th e facts and circumstances leading to the
significant gain on sale of property, plan t and equipment recorded during fiscal
year 2005.  Refer to paragraph 47 of SFAS 144 and Rule 5-03(b)(6) of Regulation S-X.  Additionally, given that over 40% of your reported earnings before income
taxes in fiscal year 2005 related to these gains, pl ease revise your MD&A to
discuss in a reasonable amount of deta il and with an appropriate level of
prominence the significant fiscal year 2005 gains and the related impact on your reported results of operations.

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 4
Consolidated Statements of Shareholders’ Equity, page 20

7. Please disclose reclassification adjustment s and the amount of income tax expense
or benefit allocated to each component  of other comprehensive income on the
face of the statements of shareholders’ e quity or in the notes to the financial
statements.  Refer to paragraphs 20 and 25 of SFAS 130.

Notes to Consolidated Financial Statements, page 22

Note 1. Summary of Significant Accounting Policies, page 22

8. Please disclose the types of expenses th at you include in the cost of goods sold
line item and the types of expenses that you include in the selling and administrative expenses line item.  In  doing so, please disclose specifically
whether you include purchasing and r eceiving costs, inspection costs,
warehousing costs, internal transfer cost s and the other costs of your distribution
network in cost of goods sold.  With the exception of ware housing costs, if you
currently exclude a signifi cant portion of these costs from cost of goods sold,
please provide cautionary disclosure in MD&A that your gross margins may not
be comparable to others, since some entitie s include all of the costs related to their
distribution network in cost of goods sold  and others exclude a portion of them
from gross margin, including them instead in operating expense line items.  To
the extent the excluded costs are material  to your operating results, quantify these
amounts in MD&A.  If you determine th at these amounts are immaterial for
disclosure, please provide us with your qualitative and quantitat ive assessment of
materiality for all periods presented.

d) Revenue Recognition and Allowance for Doubtful Accounts, page 22

9. To the extent material please revise to  disclose information related to your
provision for sales returns in Schedule II – Valuation and Qualifying Accounts.
Alternatively, you may include this inform ation in your footnotes.  See Rules 5-04
and 12-09 of Regulation S-X.

f) Shipping and Handling Fees and Costs, page 22

10. Please tell us and revise your disclosure  to clarify the natu re of the “other”
shipping and handling costs included in sel ling and administrative expenses.  Also
explain to us why these particular shi pping and handling costs are classified as
selling and administrative expenses, while  the remainder of your shipping and
handling costs is classified as  cost of goods sold.

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 5

Note 12.  Stock Options, page 33

11. Please revise your disclosure to di saggregate stock options from stock
appreciation rights (SARs) in  the tables, as information with respect to exercise
prices, such as weighted average exercise prices and the range of exercise prices,
would not appear to be app licable to stock appreciation rights.  Refer to paragraph
A240.f. of SFAS 123(R).  In the separate disclosures with re spect to your SARs,
please disclose the number and weighted-average grant date fair value for SARs outstanding at the beginning of the year, t hose outstanding at the end of the year,
and those granted, vested, or forfeited during the year.  Refer to paragraph
A240.b.(2) of SFAS 123(R).  In addition, pleas e tell us and revise  to clarify what
the “total” column represents in the tabl e on page 33 and what the “related party
options” and “other options” columns repres ent in the table on page 34.  Lastly,
with reference to SFAS 128, please tell us  and disclose how you treat SARs in
your calculation of earnings per share.

Exhibits 31.1 and 31.2

12. Please revise your certifications to read ex actly as set forth in Item 601(b)(31) of
Regulation S-K.  In particular, replace “a nnual report” with “report.”  Also revise
to include the parenthetical language that is required in paragraphs 4.d. and 5.

Form 10-Q for Fiscal Quarter Ended September 30, 2007

13. Please address the comment s above as applicable.

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
responses to our comments.  Please su bmit your response letter on EDGAR.

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filings to be certain that the filings include all information required under the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 6
In connection with responding to our co mments, 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 filings;

• staff comments or changes to disclosu re in response to staff comments do
not foreclose the Commission from ta king any action with respect to the
filings; and

• the company may not assert staff comments as a defense in any
proceeding initiated by the Commissi on or any person under the federal
securities laws of the United States.

  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

If you have any questions regarding these comments, please direct them to Adam
Phippen, Staff Accountant, at (202) 551-3336.  In his absence,  direct your questions to
Robyn Manuel at (202) 551-3823.  A ny other questions may be directed to me at (202)
551-3344.

Sincerely,

 William Thompson
Branch Chief