SecProbe.io

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October 19, 2005

Jay Ingram, Esq.
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

RE:   Fit For Business International, Inc. ("FFB")
      Registration Statement on Form SB-2
      File No. 333-122176

Dear Mr. Ingram:

We have reviewed your October 12, 2005 letter and have the following responses:

General
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1.       We note your revisions in response to our prior comments 6 and 7. We
         are not looking for a Rule 144 analysis as it pertains to future
         resales of the referenced securities but, instead, are seeking an
         analysis as to how the prior sales meet the conditions of Rule 144.
         Revise or advise. In the alternative, explain why Rule 144 does not
         apply. We may have further comment. Disclose the date each sale was
         made by Ft. Street Equity to each individual.

ANSWER: In Amendment No. 6 to Form SB-2, we have provided a Rule 144 analysis as
to how the prior sales by Fort Street Equity have met the conditions of Rule 144
(except for certain option sales by Fort Street Equity). We have also provided a
Regulation S analysis since the Fort Street transactions were offshore resales
undertaken by a person other than the issuer, a distributor or their affiliates.
We have also provided a Rule 144 analysis for Mark A. Poulsen and Mark A.
Poulsen & Associates Pty Ltd. In addition, in the Stock Options section on Page
57, we have added the dates that each option sale was made by Fort Street
Equity.

Management's Discussion and Analysis of Plan of Operation, page 17
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Liquidity and Capital Resources, page 22
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2.         On page 23 you state, "[a]s of August 25, 2005, there have been no
           modifications to the second extension agreement to the License
           agreement, or changes in any of its terms." Revise to update this
           disclosure as of the most recent date practicable.

ANSWER: In Amendment No. 6 to Form SB-2, we have updated this disclosure as of
October 14, 2005.

Financial Statements, page F-3
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3.         Revise to describe the nature of the restatements, made in the
           amended financial statements as of June 30, 2005, and their effect on
           net loss and net loss per share as required by paragraph 37 of APB
           20. Disclose on the face of the financial statements that they have
           been restated. The auditor should refer to the restatement in its
           report as indicated by AU Section 561.06a. Please advise your
           independent accountant to revise its report to reference the error
           correction made to the audited 2005 financial statements.

ANSWER: The nature of the correction to the restated financial statements and
effect on the net (loss), comprehensive net (loss) and (loss) per share - basic
and diluted, are described in Note 3 to the financial statements. The financial
statements have each been marked as restated. The opinion of the independent
auditor has been amended to provide a paragraph describing the correction for
2005.

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Exhibits
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4.         Please revise the legality opinion to also opine upon the shares to
           be issued by the company in this offering. Currently the legality
           opinion states that the shares to be sold by the selling shareholders
           are legally issues, fully paid and non-assessable.

ANSWER: In Amendment No. 6 to Form SB-2, we have revised the legality opinion to
also opine upon the shares to be issued by the company in the offering.

Very truly yours,

ANSLOW & JACLIN, LLP

BY: /s/ ANSLOW & JACLIN, LLP
        ANSLOW & JACLIN, LLP
RIA/

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