SecProbe.io

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Mail Stop 3561

      August 4, 2005

Mr. Clinton H. Howard
Chief Executive Officer
Royal BodyCare, Inc.
2301 Crown Court
Irving, Texas 75038

	Re:	Royal BodyCare, Inc.
      Form 10-K for the Year Ended December 31, 2004
		Filed March 31, 2005
      File No. 0-50417

Dear Mr. Howard:

		We have reviewed your filing and have the following
comments.  We have limited our review to your financial statements
and related disclosures and will make no further review of your
document.  Where indicated, we think you should revise your
document
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 we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the Year Ended December 31, 2004

General

1. Our records show your File Number is 0-50417, rather than file
number 33-20323 that appears on the cover pages of your Forms 10-K
and 10-Q.  In future filing please include the correct File
Number.

Controls and Procedures, page 20

2. We note management`s conclusion "that our disclosure controls
and
procedures were functioning effectively to provide reasonable
assurance that the information required to be disclosed by us in
reports filed under the Securities and Exchange Act of 1934, as
amended, is recorded, processed, summarized and reported with the
time periods specified in the SEC`s rules and forms."  Please
amend
your filing:
* to state that your principal executive officer and principal
financial officer concluded that your disclosure controls and
procedures are effective at the reasonable assurance level as of
the
end of the period; and
* to clarify that your disclosure controls and procedures are
designed to provide reasonable assurance of achieving their
objectives or remove the reference to level of assurance.
If you include a definition of disclosure controls and procedures
in
the conclusion, please include the complete definition as defined
in
Rule 240.13a-15(e) or 240.15d-15(e) of the Exchange Act.  See Item
307 of Regulation S-K.  Also, refer to Section II.F.4 of
Management`s
Reports on Internal Control over Financial Reporting and
Certification of Disclosure in Exchange Act Periodic Reports, SEC
Release No. 33-8238, available on our website at
http://www.sec.gov/rules/final/33-8238.htm.

Signatures, page 24

3. The report must also be signed by your principal accounting
officer in the second signature block.  Any person who occupies
more
than one of the specified positions must indicate each capacity in
which he or she signs the report.  Please file an amendment
containing the signature of your principal accounting officer.
See
paragraph 2(a) of General Instruction D to Form 10-K.

Financial Statements
Consolidated Statements of Operations, page F-4

4. Please tell us the items and their amounts included in loss on
disposition of assets classified in operating expenses and non-
operating expenses for each period presented.  Please also tell us
your basis in GAAP for each of the items included in loss on
disposition of assets classified as non-operating expense.  Please
refer to paragraph 25 of SFAS 144 and Rule 5-03(b)(9) of
Regulation
S-X.

Note Q - Related Party Transactions, page F-25

5. Please tell us how you account for premiums paid on the split
dollar life insurance arrangement and whether you controlled the
surrender decision.  Please also tell us how you determined the
carrying value of cash surrender value at each balance date and
explain to us why the transfer of the insurance policy and
cancellation of the collateral assignment agreement resulted in a
loss.  Please refer to FASB Technical Bulletin No. 85-4.  Please
also
tell us how you classified the increase in cash surrender value in
your statements of cash flow.  Please refer to AICPA Technical
Practice Aid 1300.13.

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed letters greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

      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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed decision.  Since the company and
its management are 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 connection with responding to our comments, please
provide,
in writing, a 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Bill Thompson (Staff Accountant) at (202)
551-
3344 or the undersigned at (202) 551-3716 if you have any
questions
regarding these comments.

	Sincerely,

								William Choi
								Accounting Branch Chief

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Clinton H. Howard
Royal BodyCare, Inc.
August 4, 2005
Page 1

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

         DIVISION OF
CORPORATION FINANCE

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