SecProbe.io

December 15, 2010
 Mr. Michael Benstock Chief Executive Officer Superior Uniform Group, Inc. 10055 Seminole Blvd. Seminole, FL 33772
Re: Superior Uniform Group, Inc.
 Form 10-K for the Fiscal Year Ended  December 31, 2009
Filed February 26, 2010
 File No. 001-05869  Schedule 14A  Filed March 15, 2010

Dear Mr. Benstock:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended December 31, 2009

 Item 7.  Management’s Discussion and Analysis, page 11

1. The Management’s Discussion and Analysis sec tion is one of the most critical aspects of
your disclosure.  As such, please confirm that in future filings you will revise this section
to provide a more detailed  executive overview to disc uss the events, trends, and
uncertainties that management views as most  critical to your future revenues, financial
position, liquidity, plan of operations, and resu lts of operations, to the extent known and
foreseeable.  To assist you in this rega rd, please refer to the Commission Guidance
Regarding Management’s Discussion and Analys is of Financial Condition and Results of
Operations, Release Nos. 33-8350 (December 19, 2003) at
http://www.sec.gov/rules/interp/ 33-8350.htm.  This guidance is  intended to elicit more

Michael Benstock Superior Uniform Group, Inc. December 15, 2010 Page 2

meaningful disclosure in MD &A in a number of areas, in cluding the overall presentation
and focus of MD&A, with general emphasis on the discussion and analysis of known
trends, demands, commitments, events a nd uncertainties, and specific guidance on
disclosures about liquidity, capital re sources, and critical accounting.
 Operations, page 11

2. Please confirm that in future filings you will provide a more detailed discussion as to the
reason(s) for the results of operations.
 Liquidity and Capital Resources, page 11

3. We note you include advances to suppliers as  a component of your accounts receivable
balance.  We also note at December 31, 2009, you had an advance to a supplier in Haiti of approximately $1.3 million.  Please (i) provi de us with the current status of this
receivable (i.e. were products  received from the supplier subsequently to offset such
advance), (ii) provide us with the total am ount of advances included in your accounts
receivable and (iii) confirm in  future filings you will disclose  the amount of advances to
suppliers included in your accoun ts receivable balance to provide an investor with a
better understanding of your accounts receivable  from customers versus advances to
suppliers.
 Exhibits

4. We note that exhibits 4.1, 4.2, 4.3, and 4.4 are missing exhibits, schedules and/or
attachments.  Please confirm that you will file these exhibits in their entirety with your
next periodic report.
 Schedule 14A filed March 15, 2010

 Management, page 4

5. On page four you present biographic info rmation for your directors and include a
statement that, “[t]ogether, the experience a nd attributes included  below provide the
reasons that these individuals are nominate d for re-election.”  Please note that the
requested disclosure pursuant to revise d Item 401(e) of Regulation S-K requires
disclosure on an individualized basis.  For guidance your attention is directed to
Regulation S-K CDI 116.05.  Pleas e provide us with draft di sclosure and confirm that
you will comply in future filings.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are

Michael Benstock Superior Uniform Group, Inc. December 15, 2010 Page 3

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 responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Blaise Rhode s at (202) 551-3774 or Brian Bhandari, Accounting Branch
Chief, at (202) 551-3390 if you have questions regarding comments on the financial statements
and related matters.  Please contact Shehzad Ni azi at (202) 551-3121 or Pamela Howell, Special
Counsel, at (202) 551-3357 w ith any other questions.
 Sincerely,

John Reynolds
Assistant Director