SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 3-09

							December 8, 2004

Arnold Hantman
Chief Executive Officer
SFBC International, Inc.
11190 Biscayne Boulevard
Miami, Florida 33181

Re:	SFBC International, Inc.
	Registration Statement on Form S-3
	File Number 333-120152

Dear Mr. Hantman:

	We have reviewed your filing and have the following comments.
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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 S-3

Selling Securityholders, page 18

1. We note the disclosure you are proposing in response to comment
1.
In addition to this disclosure, please further revise footnote (2)
in
the Selling Securityholders section to identify which sellers are
broker-dealers and which sellers are affiliates of broker-dealers.
Alternatively, you may choose to use two footnotes: one
identifying
broker-dealers and one identifying affiliates of broker-dealers.
Also, for the Plan of Distribution section, in addition to the
language you have proposed, you should identify in that section
the
sellers who are broker-dealers.

2. We note your response to comment 3 and reissue the comment.
Unless the natural persons who have voting and investment control
of
the securities being offered can be ascertained by looking at the
holders` SEC filings, your registration statement should identify
the
natural persons.  Please revise accordingly, or confirm for us
that
all holders are public companies such that the natural persons who
have voting and investment control can be identified through the
holders` SEC filings.

3. We note your response to comment 4 and reissue the comment.  We
interpret the referenced telephone interpretation to mean that you
may file a prospectus supplement in order to add names of selling
shareholders when you are substituting one selling shareholder
name
for another selling shareholder name.  In order to use this
mechanism, you must be able to trace the ownership of the
securities
for the selling shareholder that is being added to a previous
owner
that was previously identified in the table.  If you are unable to
do
this, the new selling shareholder must be identified in a post
effective amendment.

If you file a post effective amendment for the sole purpose of
identifying additional selling securityholders, selling
shareholders
that were previously identified in the selling securityholder
table
may continue to use the prospectus.

We note your discussion relating to Proposed Rule - Securities
Offering Reform (Release No. 33-8501).  Please note, if this rule
is
adopted it will constitute a change from our current position.

*	*	*

	As appropriate, please amend your registration statement in
response to these comments.  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 supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	Please contact Greg Belliston at (202) 824-5219 or me at
(202)
942-1840 with any questions.

							Sincerely,

							Jeffrey P. Riedler
							Assistant Director

cc:	Alison W. Miller, Esq.
	David M. Seifer, Esq.
	Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A.
	150 West Flagler Street, Suite 2200
	Miami, Florida 33130
??

??

??

??

Arnold Hantman
SFBC International, Inc.
December 8, 2004
Page 1

</TEXT>
</DOCUMENT>