SecProbe.io

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Mail Stop 3561

      							October 4, 2005

Jon F. Chait
Chief Executive Officer
Hudson Highland Group, Inc.
622 Third Avenue
New York, NY 10017

	Re:	Hudson Highland Group, Inc.
      Form 10-K for Fiscal Year Ended December 31, 2004
		Filed March 14, 2005

		Forms 10-Q for Fiscal Quarters Ended
      March 31, 2005 and June 30, 2005
		File No. 0-50129

Dear Mr. Chait:

      We have reviewed your supplemental response letter dated
September 8, 2005 as well as your filing and have the following
comments.  As noted in our comment letter dated August 25, 2005,
we
have limited our review to your financial statements and related
disclosures and do not intend to expand our review to other
portions
of your documents.

Form 10-K for Fiscal Year Ended December 31, 2004

Note 15.  Segment and Geographic Data, page 63

1. We note your response to comment 2.  In order to help us
evaluate
your analysis of operating and reportable segments, please tell us
how you have identified your chief operating decision maker and
provide us with an example of all of the reports provided on a
regular basis to the chief operating decision maker.  In addition,
please address the following items:

* It is unclear to us why you do not believe your temporary and
contract staffing, permanent recruitment of mid-level
professionals,
and related human capital solutions activities are operating
segments
under paragraph 10 of SFAS 131.  Since you have gross margin
information for each type of activity, it appears that this
information would constitute discrete financial information.

* In light of the above comment, tell us how you have considered
the
guidance in paragraph 15 of SFAS 131 regarding the evaluation of
segments in a matrix organizational structure.

* If you continue to believe that your regions constitute your
operating segments, please provide us with additional quantitative
information that supports your position that the regions have
similar
economic characteristics.   In this regard, based on our review of
the financial results for the years ended December 31, 2003 and
2004
and the six months ended June 30, 2005, it appears that the
Americas
region has consistently earned lower gross margins and the
European
region has consistently earned higher gross margins than the Asia
Pacific region.  In addition, it appears that Adjusted EBITDA
margin
percentages have varied across all regions for each time period.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  You may contact
Kathleen Kerrigan, Staff Accountant, at (202) 551-3369 or Melissa
Hauber, Senior Staff Accountant, at (202) 551-3368 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3810 if you have any
other
questions.

								Sincerely,

								Larry Spirgel
								Assistant Director

Mr. Jon Chait
Hudson Highland Group, Inc
October 4, 2005
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