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October 22, 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 respons e filed September 23, 2010 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 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.  Form 10-K for the Year Ended D ecember 31, 2009, filed on March 15, 2010

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

Reclassification, page 57

1. We note from your response to comment three of our letter dated September 3, 2010 that
you believe adjusted EBITDA is a non-GAAP measure you consider important to the
readers of your financial statements.  Please tell us why you do not discuss and analyze adjusted EBITDA in your filings considering its importance to readers of your financial
statements.

2. We note that you reconcile adjusted EBITDA to income from operations.  We generally
believe that net income is the GAAP measure most directly comparable to adjusted EBITDA when it is used as a performance measure.  Please reconcile adjusted EBITDA
to net income or tell us why you do not believe it is the most directly comparable GAAP
measure.

Howard G. Berger
RadNet, Inc. October 22, 2010 Page 2  Part IV

 Item 15. Exhibits

3. We note your response five in your lette r dated September 23, 2010 and we reissue
the comment.  The fact that exhibits 10.14, 10.17, 10.21, 10.23, 10.26, 10.27, 10.28, and 10.29 to the Form 10-K are no longer ma terial contracts of the Company and
have expired does not preclude the necessity to file these in their entirety, as these
were material contracts when filed pursuan t to Item 601(b)(10) of Regulation S-K.
As previously requested, exhibits 10.14, 10.17, 10.19, 10.21, 10.23, 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 are missing exhibits, schedules or attachments.  In your next periodic
report, please file these exhi bits in their entirety as re quired by Item 601(b)(10) of
Regulation S-K or advise.

DEF 14A for Annual Meeting on June 3, 2010

4. We are unable to locate your response to  comment seven from the September 3, 2010
letter and therefore we rei ssue that comment. While we note the statement that you do
not have a specific policy rega rding diversity, you have not disclosed whether, and if
so how, the nominating committee considers diversity in identifying nominees for
directors, as required by Item  407(c)(2)(vi) of Regulation S-K.  Please confirm that
you will provide such disclosure in future filings.  Please provide us with sample disclosure.
  Closing Comments

              You may contact Brian Mc Allister, staff accountant at  (202) 551-3341 or Ryan
Milne, accounting reviewer at (202) 551-3688 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:  Linda G. Michaelson, Esq.        Via facsimile at (310) 228-3701

Howard G. Berger
RadNet, Inc. October 22, 2010 Page 3