SecProbe.io

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June 30, 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 May 25, 2005 letter and have the following responses:

General
-------

1.       We note your  revisions  in  response  to our  prior  comment 1 further
         noting that you have set varying offering prices for the same security.
         Describe for us the basis for setting  varying  offering prices and how
         you plan to conduct this offering  given the varying  offering  prices.
         Otherwise,  revise your disclosure in accordance with our prior comment
         1. We also note that the price  being  offered by the  company  differs
         from the offering by the selling shareholders. Please explain the basis
         for the varying  offering  prices and how the company  plans to conduct
         this  offering  when its shares are offered at a  substantially  higher
         price then the selling shareholders. We may have further comment.

ANSWER:  In Amendment No. 2 to Form SB-2, we have revised the offering prices to
be $1.50 for all shares being offered.

2.       We reissue our prior comment 10. Please provide the disclosure required
         by Item 510 of Regulation  S-B;  Disclosure  of Commission  Position on
         Indemnification for Securities Act Liabilities on the prospectus.

ANSWER: As previously  indicated in our response to prior comment 4 (not comment
10), the original filed SB-2  registration  statement  contained the information
required by this question in Item 24 (Commission's  position on indemnification)
and Item 28(B)  (undertaking in the first sentence of Item 512(e)).  If there is
another  place in the  document  that  this  disclosure  is  required,  we would
respectfully request guidance from the Commission.

3.       It appears that Herbalife  Ltd.,  rather than  Herbalife  International
         Inc.  is  traded  on the NYSE  under  the  symbol  HLF.  Please  revise
         throughout  the  prospectus.  Also,  please  disclose the  relationship
         between  Herbalife  Ltd. and Herbalife  International  Inc. and clarify
         your relationship with each.

<PAGE>

ANSWER:  Herbalife Ltd. is the company traded on the NYSE. Herbalife Ltd. is the
supplier of the nutritional  products that Fit For Business uses in its wellness
programs. Fit for Business does not know the relationship between Herbalife Ltd.
and Herbalife  International  Inc.  However,  pursuant to Herbalife Ltd's latest
Form 10-K filing, Herbalife International Inc. is a subsidiary of Herbalife Ltd.
We have  revised  Amendment  No. 2 to Form  SB-2,  to change all  references  to
Herbalife Ltd.

Registration Statement Facing Page
----------------------------------

4.       We note that the  information  required by Item 501(a)(9) of Regulation
         S-B  appears  on page 3. Since you  disclose  this  information  on the
         prospectus cover page, please remove the disclosure from page 3.

ANSWER:  Page 3 of the document is the balance of the registration fee table. It
does not discuss the information required by Item 501(a)(9). Please clarify this
question so that we can address this issue.

Prospectus Cover Page
---------------------

5.       We reissue our prior comment 5. Review the disclosure  requirements set
         forth in Item 501 of  Regulation  S-B and limit your  disclosure on the
         cover page to only that information  required by the Item.  Please note
         that the disclosure of extraneous  information  that is not required by
         Item 501 of  Regulation  S-B  greatly  impairs the  readability  of the
         disclosure  on the cover  page.  For  example,  we refer  you,  without
         limitation,  to  disclosure  referencing  the use of  proceeds  and the
         identity of the option holders.

ANSWER:  We have  revised the cover page to comply  with Item 501 of  Regulation
S-B.

6.       We reissue our prior comment 6. Please limit the outside front cover of
         the prospectus to one page. Refer to Item  501(a)(9)(iii) of Regulation
         S-B .

ANSWER:  In Amendment  No. 2 to Form SB 2, we limited the outside front cover of
the prospectus to one page.

7.       We partially  reissue comment 7. Please disclose  whether there are any
         minimum purchase  requirements,  as required by Item  501(a)(9)(iii) of
         Regulation  S-B.  This is the minimum  number of securities an investor
         may purchase.

ANSWER: In Amendment No.2 to Form SB-2, we have stated that there are no minimum
purchase requirements. This was also contained in our original SB-2 filing.

8.       Review  your  disclosure  on the cover  page and  revise to delete  all
         repetitious  information.   For  example,  we  refer  you  to  disclose
         referencing the terms of the offering.

ANSWER:  In  Amendment  No.  2 to  Form  SB-2,  we  have  eliminated  repetitive
disclosure.

<PAGE>

9.       We partially  reissue our prior comment 8 continuing to note  reference
         to the term "recognized exchange." Clarify what you mean by your use of
         the term.

ANSWER:  In Amendment  No. 2 to Form SB-2,  this has been deleted since the only
exchange that the Company intends to be quoted on is the OTC Bulletin Board.

10.      Please remove the statement that after  effectiveness you plan to apply
         for quotation on the OTC Bulletin Board from the prospectus cover page.

ANSWER:  In Amendment No. 2 to Form SB-2,  we have removed the  above-referenced
statement.

11.      The  cross-reference  to the  "Risk  Factors"  section  is not  correct
         because the "Risk  Factors"  section  commences  on page 10.  Revise as
         appropriate.

ANSWER:  In  Amendment  No. 2 to Form SB-2,  we have  inserted  the correct page
number reference to the Risk Factors section.

12.      The Company's  supplemental response to our prior comment 11 appears to
         be incorrect  since you have not removed the  disclosure  referenced in
         prior  comment.  We thus  reissue  our  previous  comment 11. We do not
         understand  what you mean when you disclose that "[t]this  registration
         statement  will  be  amended  and  completed  from  time  to  time,  as
         necessary." Revise or advise.

ANSWER:  In Amendment No. 2 to Form SB-2, we have deleted this section.

Inside Front and Outside Back Cover Page
----------------------------------------

13.      The Company's  supplemental response to our prior comment 12 appears to
         be incorrect  since it does not appear as though you have  provided the
         dealer  prospectus  delivery  obligation.  We,  therefore,  reissue the
         comment. Refer to Item 501(b) of Regulation S-B.

ANSWER:  In Amendment No. 2 to Form SB-2, we have provided the dealer prospectus
delivery obligation.

Application of Proceeds
-----------------------

14.      Please  remove this section  since you  prospectus  includes a detailed
         "Use of Proceeds"  section in  accordance  with Item 504 of  Regulation
         S-B.

ANSWER: In Amendment No. 2 to Form SB-2, we have removed this section.

Risk Factors
------------

15.      We reissue our prior  comment 21.  Please avoid the generic  conclusion
         you reach in many of your risk factors  that you risk could  negatively
         impact or have an  adverse  effect on your  business  or your  business
         could suffer negative consequences. Instead, replace this language with
         specific  disclosure  of how  your  business  and  operations  would be
         affected. Refer to the second, seventh, and fifteenth risk factors.

ANSWER: In Amendment No. 2 to Form SB-2, we have revised the generic conclusions
and replaced such language with specific risk disclosure.

16.      Please  revise the first risk factor  subheading  to revise the risk to
         the company and investors relating to the going concern. The risk would
         appear to be that the  company may cease to exist and  investors  could
         loose their money,  rather than simply hurting the company's ability to
         raise additional financing.  Also, update the deficit accumulated as of
         most recent financial statements in the risk factor.

<PAGE>

ANSWER:  In Amendment  No. 2 to Form SB-2, we have revised the first risk factor
subheading.

17.      Please remove risk factor thirteen.

ANSWER: In Amendment No. 2 to Form SB-2, we have removed risk factor 13.

Since Our Business Operations Are Presently Located. . . ."
-----------------------------------------------------------

18.      Please  expand  the  disclosure  in this risk  factor to  provide  more
         specific information about the "rules and regulations" of Australia and
         how they may impact your operations.  Currently,  the disclosure is too
         general.

ANSWER:  In  Amendment  No.  2 to Form  SB-2,  we have  added  disclosure  about
Australian rules and regulations.

Use of Proceeds
---------------

19.      We partially  reissue prior comment 25. Please provide more specificity
         regarding  the amount  allocated to working  capital.  Please revise to
         indicate the amount allocated to each use of working capital.

ANSWER:  In Amendment  No. 2 to Form SB-2,  we have  specifically  allocated the
working capital to 5 specific areas.

20.      We note that the proceeds  will be used to pay salaries of  management.
         Please include a separate line in the use of proceeds table  indicating
         the total amount allocated to these salaries.

ANSWER:  In Amendment  No. 2 to Form SB-2,  we have  included a separate  salary
line.

21.      Please  discuss  the  allocation  of  proceeds  if you raise  less than
         $700,000.

ANSWER;  In Amendment No. 2 to Form SB-2, per our  discussion,  we have added an
allocation for $350,000.

Management's Discussion and Analysis
------------------------------------
Overview
--------

22.      In the second  paragraph,  explain your use of the term  "deemed" as it
         relates to the disclosure about the reverse merger.  Also,  explain the
         business purpose of the reverse merger.

<PAGE>

ANSWER:  The use of the word  "deemed"  as it relates to the  disclosure  of the
reverse merger comes from the  information  contained in Statement of Accounting
Financial Standards No. 141 - Business  Combinations,  (SFAS No. 141), paragraph
17 which  states:  "In a business  combination  effected  through an exchange of
equity  interest,  the entity  that issues the equity  interests  is general the
acquiring entity. In some business combinations (commonly referred to as reverse
acquisitions),  however,  the acquired  entity issues the equity  interests." As
such,  the  use  of  the  word  "deemed"  refers  to  an  entity  identification
application of the acquiring entity and the acquired entity.  In the case of Fit
For  Business  International,  Inc.  ("FFB  International"  and Fit For Business
Australia  Pty  Limited  ("FFB  Australia"),   FFB  International  is  a  Nevada
corporation  with no assets,  working capital or operations.  FFB Australia is a
private  operating  company.  The merger of the private  operating  company (FFB
Australia) into the non-operating shell corporation (FFB International) resulted
in the owners and management of the private  company having actual and effective
operating   control  of  the  combined  company  after  the  transaction,   with
shareholders  of the shell  company  continuing  as passive  investors.  In this
reverse acquisition  transaction,  FFB Australia is "deemed" to be the acquiring
entity, and FFB International the acquired entity,  with the continuation of the
operations of the combined  entity after the  transaction  under the name of FFB
International.

The business purpose of the reverse merger is to allow FFB Australia,  under the
name of FFB  International,  the  opportunity  to  conduct a  capital  formation
activity  through the issuance of common stock  registered  with the SEC through
the use of a  Registration  Statement  on Form  SB-2.  Considering  the  limited
resources of FFB Australia, this method of "going public" is preferred over that
of an initial public offering ("IPO") registration.

The accounting  application  involved in the reverse merger process is described
in Note 1 to the financial  statements  for the interim  periods ended March 31,
2005, and 2004,  under the heading of Basis of  Presentation  and  Organization,
presented in the SB-2/A document.

23.      In the  second  paragraph,  explain  you  use of  the  phrase  "quality
         endorsed business model."

ANSWER:  In  Amendment  No. 2 to Form SB-2,  we have  deleted this phrase as the
quality  endorsement  applies  to the  Company's  processes  rather  than to the
business model.

24.      Please specifically  disclose the factual basis for, and the context of
         all your beliefs,  understandings,  estimates,  and  opinions.  This is
         particularly  true for all  projections,  statistics,  and  assertions.
         Unless  you  can   substantiate  on  a  reasonable  basis  all  of  the
         projections,  statistics  and assertions  that you cite,  please remove
         them.  Some examples  include the following.  This is not an exhaustive
         list.
                  a.  Disclosure  referencing  the  statistics of the Australian
                  Institute  of Health and Welfare and how the  "statistics  are
                  reflected in the Australian workforce."
                  b.  Disclosure   referencing  the  Australian  National  Audit
                  Office.
                  c. On page 23,  the  disclosure  in the  paragraph  commencing
                  "[i]t  would  be  FFBI  analysis  that  within  three  to five
                  years...." d.  Disclosure on page 36, stating that "[t]he FFBI
                  program  appeals  to  a  broad   cross-section   of  potential
                  independent  Living Well  account  executives  throughout  the
                  world...."

ANSWER:  In Amendment No. 2 to Form SB-2, we have  identified  source  documents
that were the basis for the  Company's  beliefs,  understanding,  estimates  and
opinions.  We have  identified  and footnoted  the specific  references to these
documents.  Please note,  we have moved this section to the  description  of our
business section, as a consequence of revising the MD&A section as requested.

<PAGE>

25.      Please  provide the basis for the  disclosure  regarding  the company's
         beliefs  throughout  this section.  For example,  we note  management's
         belief "its approach and programs deliver a sustainable  improvement to
         employees'  lives....  [which is] reflected in their increased  health,
         more positive mental and emotional  states,  and greater  productivity"
         and your programs "improve their profitability."

ANSWER:  In  Amendment  No. 2 to Form SB-2,  we have  provided the basis for the
disclosure  regarding  the  Company's  beliefs,  understanding,   estimates  and
opinions or deleted such language.

26.      Currently the overview repeats disclosure found in the business section
         and does not add meaningful disclosure to the MD&A discussion. As such,
         we ask that you revise the  executive  overview  to discuss the events,
         trends, and uncertainties that management views as most critical to the
         company's revenues,  financial position,  liquidity, plan of operations
         and results of  operations.  In an effort to assist you in this regard,
         please  refer  to  th