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Mail Stop 0308

							November 16, 2004

Scott Gallagher
Chief Executive Officer
FTS Apparel, Inc.
1049c Oxford Valley Rd.
Levittown, PA  19057

	RE:	FTS Apparel, Inc.
		Item 4.01 Form 8-K filed November 9, 2004
            	File No. 0-24829

Dear Mr. Gallagher:

	    We have reviewed the above referenced filing and have the
following comments.  We welcome any questions you may have about our
comments.  Feel free to contact us at the telephone numbers listed at
the end of this letter.
1. Item 304(a)(1) of Regulation S-B requires you to provide
disclosures with respect to a change in accountants for the two most
recent fiscal years; however, you have only provided this information
for the most recent fiscal year and subsequent interim period.
Please revise the filing to provide disclosures with respect to
disagreements and audit reports covering two fiscal years.  If you
believe two-year disclosure is not applicable please tell us why and
revise the filing to explain the particular facts and circumstances.
2. Please revise to include the letter from your former accountant as
an exhibit to an amended filing.
3. We note that you printed the name FTS Group, Inc. on the cover of
your filing.  Our records indicate that your name is FTS Apparel,
Inc.  Please either correct the name on your amended filing or tell
us why the name you use is correct.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filing reviewed by the staff to be certain
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.

FTS Apparel, Inc.
November 16, 2004
Page 2

	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
disclosures 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 this action 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 connection with our review of your
filing or in response to our comments on your filing.

 	Any questions regarding the above should be directed to me at
(202) 942-1809, or in my absence to Robert Benton at (202) 942-1811.

							Sincerely,

							Robert Burnett
						            Staff Accountant

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