SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

 Mail Stop 3561
       November 26, 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 Ended 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 response dated November 9, 2007 to our comment letter
dated November 1, 2007 and have the following additional comments.  We think you should revise your disclosures in future filin gs 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 that we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.  Form 10-K for Fiscal Year Ended December 31, 2006

 Item 8. Financial Statements and Supplementary Data, page 18

 Consolidated Statements of Earnings, page 18

 1. We reviewed your response to comment six from our comment letter dated
November 1, 2007 and continue to believe you should revise your future filings to
show a separate line item for material  gains on sale of property, plant and
equipment.  We also continue to be lieve you should disclose the facts and
circumstances leading to the significan t gain on sale of property, plant and
equipment recorded during fiscal year 2005.  Refer to paragraph 47 of SFAS 144
and Rule 5-03(6) of Regulation S-X.  A dditionally, as previo usly indicated, we

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 26, 2007
Page 2
believe you should revise Management’s Discussion & Analysis (“MD&A”) to
discuss in a reasonable amount of deta il and with an appropriate level of
prominence the significant fiscal year 2005 gain and the related impact on your
reported results of operations.  The offse tting impact of the related relocation of
the operations of the disposed distribu tion facility that you discuss in your
response letter should likewise be  discussed in MD&A.

Notes to Consolidated Financial Statements, page 22

Note 1. Summary of Significant Accounting Policies, page 22

d) Revenue Recognition and Allowance for Doubtful Accounts, page 22
 2. We reviewed your response to comment  nine from our comment letter dated
November 1, 2007.  For each period presented, please demonstrate for us that the
activity in your allowance for sales returns is immaterial for disclosure.  In this
regard, for each period presented, please te ll us the balance at the beginning of the
period, the amount charged to expense dur ing the period, deductions from the
allowance during the period, and the balance at the end of the period.  Otherwise,
as previously requested, please revise to  disclose information related to your
provision for sales returns either in Schedule II – Valuation and Qualifying
Accounts or in your audited footnotes.  See Rules 5-04 and 12-09 of Regulation
S-X.
 Note 12. Stock Options, page 33

 3. We reviewed your response to comme nt 11 from our comment letter dated
November 1, 2007 and continue to believe  you should revise your disclosure to
disaggregate stock options from stock a ppreciation rights (SARs) in the tables
since certain information with respect to exercise prices, such as weighted average exercise price and range of exercise prices , would not appear to be applicable to
SARs.  If you believe we are misunders tanding the nature and terms of your
SARs, please advise.  In the separate disclosures with respect 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).  Al so, please further clarify what the “total” column
represents in the table on page 33, or otherwise remove this  information from
your future filings.  Lastly, as previo usly requested, please tell us what the
“related party options” and “other options” columns represent in the table on page
34.

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a letter that keys your

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 26, 2007 Page 3  responses to our comments and provides a ny requested information.  Detailed response
letters greatly facilitate our review.  Pl ease submit your respon se letter on EDGAR.
Please understand that we may have additiona l comments after reviewing your responses
to our comments.
 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