SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

October 20, 2005

Mr. Dennis N. Cavender
Executive Vice President, Chief Financial Officer and Secretary
Essential Group, Inc.
1325 Tri-State Parkway, Suite 300
Gurnee, Illinois 60031

      Re:	Essential Group, Inc.
		Form 10-K for the Fiscal Year Ended December 31, 2004
		Filed March 30, 2005
		File No. 005-77938

Dear Mr. Cavender:

      We have reviewed your response dated August 12, 2005 to our
comment letter dated August 2, 2005 and have the following
comments.
In our comments, we have asked 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.

Consolidated Financial Statements

Notes to Consolidated Financial Statements, page F-7

1.  Lines of Business, page F-7

1. Please clarify how the site management, patient recruitment,
and
contract research organization services represent "a single group
of
similar services", as you asserted in your response to prior
comment
one and as contemplated by paragraph 37 of SFAS 131.  In so doing,
please tell us how this is consistent with your assertion that the
"distinction in brand names is related to the scope and breadth of
services contracted and provided," as their "breadth" would not
appear to suggest that they are "similar."

3. Summary of Significant Accounting Policies, page F-9

Revenue Recognition, page F-10
2. Regarding your response to comment two,  please tell us why
recognizing revenue based on hours worked is appropriate under SAB
104, as you stated that your contracts identify services that can
be
billed on a stand alone basis at specific prices for the
particular
services performed.  In this regard, it would appear that the
service
is an output measure upon which revenue should be recognized,
while
hours worked would appear to be an input measure.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provide the
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.

      You may contact Tabatha Akins, Staff Accountant, at (202)
551-
3658 or Oscar Young, Senior Staff Accountant, at (202) 551-3622 if
you have questions regarding the comments.  Please contact me at
(202) 551-3679 with any other questions.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief
Accountant

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Dennis N. Cavender
Essential Group, Inc.
October 20, 2005
Page 2

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