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September 3, 2010                                                                                                        Howard G. Berger, M.D.  Principal Executive Officer RadNet, Inc. 1510 Cotner Avenue Los Angeles, CA  90025         RE:  RadNet, Inc.
               Form 10-K for FYE December 31, 2009
               Filed March 15, 2010, amended March 31, 2010 and May 10, 2010;                DEF 14A for Annual Meeting on June 3, 2010                Filed April 23, 2010                File No. 1-33307

Dear Dr. Berger:          We have reviewed your filings a nd 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 with in ten 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 circumstances, please tell us why in your
response.
          After reviewing the information you provide in response to these comments, we may
have additional comments.  Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 34
 Year Ended December 31, 2009 Compared to  the Year Ended December 31, 2008, page 37

1. We note your tables providing the percentages of payments by both modality and
payor, and average dollar payments by modality for each of the last three fiscal years
at page 11 within your Form 8-K file d March 15, 2010.  One of the principal
objectives of MD&A is to gi ve readers a view of the company through the eyes of
management by providing an analysis of th e business.  Please tell us whether your
respective percentages of payments by pa yor or modality and your average dollar
payments by modality represent key measures by which you manage your business, and if so, expand your MD&A to disclose a nd analyze such measures.  Alternatively,
tell us why such analysis would not be mate rial to an investor’s  understanding of your
business.   Refer to FRC 501.12.b.1. for additional guidance.

Howard G. Berger, M.D.
RadNet, Inc. September 3, 2010 Page 2  Operating Expenses, page 37

2. If you continue to present this table pl ease remove the characterization “Operating
expenses” from the subtotal preceding depr eciation and amortization.  We refer you
to the definition of non-operating expenses in Rule 5-03(b)(9) of Regulation S-X.
 Notes to Consolidated Financial Statements, page 56

 Note 2 – Summary of Significan t Accounting Policies, page 57

 Reclassification, page 57

3. We note your disclosure describing the reclas sification of management fees billed to
your non-consolidated joint ventures.  Please tell us the amount of these
reclassifications in each of the presente d periods and provide additional detail
describing the nature of these transactions .  Explain for us the accounting basis for
your revised classification, in cluding any relevant guidan ce.  Tell us why you have
not classified the adjustment as a correcti on of an error, in accordance with ASC 250-
10-45-23.
   Note 3 – Facility Acquisitions, page 61

4. Please disclose the information require d by FASB ASC 805-10-50-2e. through 2h. in
future filings for individually immaterial business combinations occurring during the reporting period that are collectively material.  See FASB ASC 805-10-50-3.
Specifically, expand your discussion to di sclose the requirements prescribed by
FASB ASC 805-10-50-2f. and h.  Please provide us with an example of your revised
disclosure.
Part IV

 Item 15. Exhibits

5. We note that exhibits 10.14, 10.17, 10.19, 10.23 10.21, 10.26, 10.27, 10.28, 10.29,
and 10.30 to the Form 10-K and Exhibit 10.1 to the Form 8-K filed April 6, 2010  do
not appear to be executed copies, in that th ey appear to have some blank spaces.  In
your next periodic report, please file these e xhibits in their entirety as required by
Item 601(b)(10) of Regulation S-K or advise.

6. In addition, we note that exhibits 10.15, 10.16, 10.18, 10.20, 10.22, and 10.24 were
filed in an improper electronic format.  Pl ease note that while you may file electronic
documents as an image as an unofficial copy, you must still file your  exhibits with an
acceptable electronic format.  Refer to Rule  102(a) of Regulation S-T and Section 2.1
of Volume II of the EDGAR Filer Manual

Howard G. Berger, M.D.
RadNet, Inc. September 3, 2010 Page 3  DEF 14A for Annual Meeting on June 3, 2010

7. While we note the statement that you do not have a specifi c policy regarding
diversity, you have not disclosed whether,  and if so how, the nominating committee
considers diversity in iden tifying nominees for directors, as required by Item
407(c)(2)(vi) of Regulation S-K.  Pleas e confirm that you will provide such
disclosure in future filings.
  Closing Comments

             We urge all persons who ar e 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 Exchan ge Act rules require.  Since the company and
its management are in possession of all facts relating to a co mpany’s disclosure, they are
responsible for the 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  and accuracy of the disclosure 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 federal securities laws of the United
States.

You may contact Brian Mc Allister, staff accountant at (202) 551-3341 or Ryan
Milne, accounting reviewer at (202) 551-3 688 if you have questions regarding comments on
the financial statements and related matters.  Please contact Janice McGuirk, examiner, at
(202) 551-3395 or Pam Howell, legal reviewer, at (202) 551-3357 with any other questions.

Sincerely,
             John Reynolds,
Assistant Director
cc:  via fax (310) 445-2980

Howard G. Berger, M.D.
RadNet, Inc. September 3, 2010 Page 4