SecProbe.io

February 22, 2011
 Mr. Ted W. Owen Chief Financial Officer Team, Inc. 200 Hermann Drive Alvin, Texas 77511
Re: Team, Inc.
Form 10-K for the fiscal year ended May 31, 2010 Filed August 6, 2010 Form 10-Q for the Fiscal Qu arter Ended November 30, 2010
Filed January 7, 2011 File No. 1-08604

Dear Mr. Owen:

 We have reviewed your filing and have the following comments.  Except where indicated, please confirm you will comply w ith our comments in future filings.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 10-K for Fiscal Year Ended May 31, 2010

 Item 7. Management’s Discussion and Analysis…, page 15

 General

1. In future filings please provide a tabular disc losure of contractual obligations pursuant to
Item 303(a)(5) of Regulation S-K.
 Critical Accounting Policies

 Goodwill and Other Intangible Assets, page 22

2. We note that goodwill represents 21% or more of your assets as of May 31, 2010.  In
light of the significance of  your goodwill balance, we exp ect robust and comprehensive
disclosure both in your footnote and in your critical accounting po licies regarding your

Mr. Ted W. Owen Team, Inc. February 22, 2011 Page 2

impairment testing policy.  This disclosure  should provide inve stors with sufficient
information about management's insights and assumptions with regard to the
recoverability of goodwill.  Specifically, plea se disclose the following information for
each reporting unit (with material goodwill) that  is at risk of failing step one of the
goodwill impairment test:

• Percentage by which fair value exceeded carrying value as of the most recent
step-one test;
• Amount of goodwill allo cated to the unit;
• Description of the methodology used  to determine fair value;
• Description of key assumptions used  and how the key assumptions were
determined; and
• Discussion of the uncertainty associat ed with the key assumptions and any
potential events and/or circumstances that  could have a negati ve effect on the
key assumptions.
 Otherwise disclose, if true, in your critical  accounting policies that none of your reporting
units with significant goodwill is at risk of  failing step one of the goodwill impairment
test.  Please provide us y our proposed disclosures.
 Item 15. Exhibits

 Note 1. Summary of Significant Accounting Policies and Practices

 Property, Plant and Equipments, page 37

3. We note that you disclose your policy for leas ehold improvements is between 2-10 years.
Please tell us how you have factored the leas e term in your determin ation of the life or
lives of your leasehold improvement(s).  In  this regard we note that leasehold
improvements should be amortized over the shor ter of their respectiv e useful life or the
lease term.
 Exhibits 31.1 and 31.2

4. We note that the certifications required by Exchange Act Rule 13a -14(a) continue to
substitute “annual report” fo r “report” in paragraphs 2 and 3, and omit language in
paragraph 4(d), namely “(the registrant’s four th fiscal quarter in the case of an annual
report).”  In future filings please revise the certifications to include all required
provisions.  See Item 601(b )(31) of Regulation S-K.
 Form 10-Q for the Fiscal Quarter Ended November 30, 2010

 Notes to the Unaudited Consolidat ed Condensed Financial Statements

Mr. Ted W. Owen Team, Inc. February 22, 2011 Page 3

7. Long-Term Debt, Derivatives a nd Letters of Credit, page 13

5. We note on page 13 that your future maturity on long-term debt in 2012 is anticipated to
be approximately $77,373,000.  In future fi lings please discuss in Management’s
Discussion and Analysis the impact of l ong-term debt maturity obligations on your
liquidity and capital resour ce including discussion of po ssible methods for managing
your debt obligations.

Please file all correspondence over EDGAR.  We urge all persons who are responsible
for the accuracy and adequacy of the disclosure in  the filing to be certain  that the filing includes
the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules
require.  Since the company and its management  are in possession of a ll facts relating to a
company’s disclosure, they are responsible for th e accuracy and adequacy of  the disclosures they
have made.                In responding to our comments, please provide 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 Michael He nderson, Senior Staff Acc ountant, at (202) 551-3365 or
Terry French, Accountant Branch Chief, at (202) 551-3828 if you have questions regarding
comments on the financial statements and rela ted matters.  Please contact Kate Beukenkamp,
Attorney-Advisor, at (202) 551-6971 or me at (202) 551-3810 with any other questions.

Sincerely,

Larry Spirgel Assistant Director