SecProbe.io

Mail Stop 3651

September 16, 2005
 Via U.S. Mail and Facsimile

 Michael S. Hedge Chief Executive Officer Datrek Miller International, Inc. 835 Bill Jones Industrial Drive Springfield, Tennessee 37172
RE: Datrek Miller International, Inc.
   Form 10-KSB for the Fiscal Year Ended December 31, 2004
File No. 000-29707
   Dear Mr. Hedge:

We have reviewed your filing and have the following comments.  We have
limited our review to only financial statements  and related disclosures and do not intend
to expand our review to othe r portions of your document.  Where indicated, we think you
should revise your document in response to  these comments a nd comply with the
remaining comments in all future filings.  If you disagree, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary.  Please
be as detailed as necessary in your explanat ion.  In some of our comments, we may ask
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 re view 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 any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Michael S. Hedge
Datrek Miller International, Inc. September 16, 2005 Page 2

Form 10-KSB for the Fiscal Year Ended December 31, 2004

 Index to Consolidated Financial Statements

 Consolidated Statements of Stockholders’(D eficiency) Equity for the Year Ended
December 31, 2004 and 2003, page F-4

1. We note from your disclosure that you have eliminated the $5,712,159
accumulated deficit amount associated with  “Miller’s accumulate d deficit at the
time of merger.”  As the acquisition of Miller by DMI is a reverse acquisition that has been accounted by you as a recapita lization, the accumulate d deficit of the
accounting acquirer ( i.e. Mill er) should be carried forw ard after the acquisition.
As such, please revise your financial stat ements to properly carry forward Miller’s
accumulated deficit at the time of merger.
 Note 1. Description of Busine ss and Acquisitions, page F-7

2. With respect to your acquisition of Da trek Professional Bags, Inc., up to
$1,000,000 of additional consideration is paya ble contingent on sales of golf bags
to Wilson Sporting Goods Co. and other golf  bag customers of the acquiree.  You
plan to record this additional consider ation as goodwill.  Because the additional
consideration is contingent on sales to cu stomers of the acquiree, we believe the
cost is directly related to acquired cust omer relationships and should be recorded
as additional customer-related intangibles, subject to amortization, rather than as
goodwill.  Please confirm your agreement with this accounting treatment and
revise your financial statements accordingly.
 Note 2. Summary of Significant Accounting Policies

Goodwill
Accounting for Long-Lived Assets
Note 5. Goodwill

3. We note from your filing that you had si gnificant net losses and negative cash
flows from operations for the past two consecutive fiscal years ending December
31, 2004 and 2003 and quarterly periods ending April 2, 2005 and July 2, 2005, an accumulated deficit of $3,605,097 as of December 31, 2004, and a full valuation allowance on deferred tax asse ts. Additionally, we note from your
disclosure on page F-18 that FCC (your  bank) has required you to maintain a
lock-box arrangement, whereby all of your cu stomer collections are deposited in a
lock-box controlled by FCC and therefore such working capital funds are used to
repay outstanding banking obligations.  In consideration of the above factors,
please advise us of the date of your long- lived asset impairment analysis for the
fiscal year ended December 31, 2004. Also  provide us with a summary of the
methodology and significant assumptions a nd estimates you considered in this

Michael S. Hedge
Datrek Miller International, Inc. September 16, 2005 Page 3

impairment analysis on an individual asset group basis, and further explain to us
why you concluded that no impairment of your long-lived asset to be held and
used was necessary for the periods presente d in the filing.  In addition, explain the
lowest level for which identifiable cash flows are largely independent of the cash
flows of other assets and liabilities in  assessing your impairment. See SFAS No.
144 for guidance.

4. Please revise your disclosure on page F-16 to describe how you assess goodwill
for impairment on a “reporting unit” basi s pursuant to para graphs 19 through 21
of SFAS No. 142. In this regard, clearl y explain how you evaluate impairment
and how you define your reporting units, supported with factors cited in
paragraphs 30 and 31 of SFAS No. 142.

 As appropriate, please amend your filing and respond to these comments within
20 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and
provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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.

Michael S. Hedge
Datrek Miller International, Inc. September 16, 2005 Page 4

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 You may contact Jeff Jaramillo at (202 ) 551-3212 or Lyn Shenk, Assistant Chief
Accountant, at (202) 551-3380 if you have  questions regarding comments on the
financial statements and related matters.  Pl ease contact Max Webb, A ssistant Director, at
(202) 551-3755 with any other questions.

         S i n c e r e l y ,           L i n d a  C v r k e l         B r a n c h  C h i e f     Via facsimile: Michael S. Hedge, Chief Executive Officer  (615) 384-1290