SecProbe.io

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Mail Stop 4561

      August 15, 2005

James J. TerBeest
Chief Financial Officer
Crdentia Corporation
14114 Dallas Parkway
Suite 600
Dallas, TX 75254

      Re:	Crdentia Corporation
		Form 10-KSB for the Year Ended December 31, 2004
		Filed March 31, 2005
		File No. 0-31152

Dear Mr. TerBeest:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
document.
In our comments, we ask you to provide us with information so we
may
better understand your disclosure.  Please be as detailed as
necessary in your explanation.  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
filings.
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-KSB for the Year Ended December 31, 2004

Note 5 - Goodwill and Other Intangible Assets, pages F-17 - F-19

1. We note your intangible asset impairment of $1,800,000.  With
respect to this impairment, please give us a more detailed
description of the facts and circumstances that led you to believe
that certain intangible assets were impaired, which reporting
unit(s)
held these impaired intangible assets, and how you came to the
conclusion that goodwill and other long lived assets within these
reporting unit(s) were not also impaired.

Note 13 - Long Term Bonus Payable, page F-26

2. Please tell us what service period these bonuses relate to and
in
which period(s) you have recognized or will recognize the
associated
expense.  In addition, please explain the terms of the bonuses and
tell us whether the amounts are forfeitable under any
circumstances.

Note 15 - Stockholders` Equity, pages F-32 - F-37

3. We note that you recorded approximately $5.8 million in
compensation expense upon the return of 1,016,000 shares of your
common stock by certain shareholders.  In light of the fact that
no
consideration was provided to these shareholders, please tell us
your
basis in GAAP for recording the compensation expense.  We are
unclear
as to what guidance in APB 25 applies to this situation.

Form 10-QSB for the Quarter Ended March 31, 2005

Note 13 - Subsequent Events, page 22

4. We note your acquisition of Prime Staff LP and Mint Medical
Staffing Odessa in May of 2005.  Please tell us whether you
evaluated
the significance of these acquisitions using the guidance in Item
310(c)(2) of Regulation S-B.

      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.  Please file your response on EDGAR.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 filings or
in
response to our comments on your filings.

      You may contact Matthew Maulbeck, Staff Accountant, at (202)
551-3466 or the undersigned at (202) 551-3403 if you have
questions.

								Sincerely,

      Steven Jacobs
      Accounting Branch Chief
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Mr. James J. TerBeest
Crdentia Corporation
August 15, 2005
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