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CORRESP
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                Rita
                  J. Leader

                  BOYER
                    &KETCHAND

                  A
                    Professional Corporation

                  Attorneys
                    At Law

                  Nine
                    Greenway Plaza, Suite 3100

                  Houston,
                    Texas 77046-0904

                  (713)
                    871-2025

                  TELEFAX
                    (713) 871-2024

www.boyerketchand.com

                rleader@boyerketchand.com

      December
        27, 2005

      Securities
        and Exchange Commission

      Division
        of Corporation Finance

      Washington
        D.C. 20549-0404

                Attention:

                Jennifer
                  Hardy, Branch Chief

                Craig
                  Slivka, Staff Examiner

        Re:
          Amendment No. 2 to Registration Statement on Form SB-2 of Flotek Industries,
          Inc.

        Ladies
          and Gentlemen:

      On
        behalf
        of our client, Flotek Industries, Inc. (the “Company”), we have filed
        contemporaneously herewith under the Securities Act of 1933, as amended (the
        “Securities Act”), Amendment No 2 to the Registration Statement on Form SB-2 of
        the Company. This Amendment responds to the comment we received from Mr.
        Slivka
        of the Securities and Exchange Commission on December 22, 2005 to identify
        the
        Selling Shareholders who are affiliates of broker-dealers.

      In
        response to that comment, we have changed the second sentence in the second
        paragraph under Selling Shareholders on page 8 of the prospectus to read
        as
        follows:

      “One
        of
        the selling shareholders, Oberweis Micro-Cap Fund, has represented to us
        that it
        is an affiliate of a broker-dealer, that it purchased the shares in the ordinary
        course of business and that at the time of purchase of the shares it had
        no
        agreements or understandings, directly or indirectly, with any person to
        distribute the shares.”

      Any
        additional comments that the Staff may have after reviewing this Amendment
        No. 2
        and the Company’s response to the Staff’s comment should be directed to
the
        undersigned or to John Boyer at (713) 871-2025. The Company will submit a
        request for acceleration of the effective date of this registration statement
        only after receiving word that the Staff has no further comments on this
        filing.

                  Very
        truly yours,

                  /s/
        Rita J.
        Leader