SecProbe.io

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December 1, 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 November 3, 2005 letter and have the following responses:

General
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     1.   We note your revisions in response to our prior comment 1. In light of
          the proximity in timing between the sale of the securities held by
          Fort Street Equity and the loans made by Fort Street to the company,
          we view the sales by Fort Street as a primary offering on behalf of
          the company. We also believe that Fort Street was acting as an
          underwriter as it relates to such sales. Because the sales took place
          during a concurrent public registration of a company offering, the
          company's filing of the SB-2 may constitute general solicitation for
          these sales which would appear to preclude the company from relying on
          a private exemption from registration for that offering. Please revise
          your disclosure to describe the impact of a possible Section 5
          violation. It would appear that you should remove the resale of these
          securities from the registration statement, reflect the amount subject
          to possible rescission on your financial statements, describe the
          matter in a note to the financial statements, add risk factor
          disclosure and provide appropriate MD&A disclosure.

ANSWER: In Amendment No. 7 to Form SB-2, we have undertaken the following: (i)
removed the resale of securities from the registration statement to all parties
that Fort Street Equity sold options to; (ii) in FFB's financial statements we
have reflected an amount subject to possible rescission and described the matter
in a footnote to the financial statements; (iii) added a risk factor disclosure;
and (iv) also added appropriate MD&A disclosure.

Liquidity and Capital Resources, page 22
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     2.   Please update the cash balance as of the most recent practicable date.

ANSWER: In Amendment No. 7 to Form SB-2, we have updated the cash balance as of
December 1, 2005.

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Certain Relationships and Related Transactions
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     3.   Please  disclose  the  dates Mr.  Poulsen  transferred  his  shares in
          reliance on the exemption from registration contained in section 4(1).
          Also, we note the statement that the Form SB-2 was publicly available
          at the time of the transactions. Please advise us as to whether the
          Form SB-2 was used in connection with these issuances in an effort to
          satisfy the provisions of Rule 144(c)(2). If another document was
          used, please provide it to us supplementally. Also, discuss whether
          the volume limitations were met. It is required, since there is not a
          market, that the amount sold within three months could not exceed one
          percent of the shares or other units of the class outstanding. Discuss
          whether this condition was met. We may have further comment.

ANSWER: FFB now takes the position that the shares transferred by Mr. Poulsen
are exempt from registration pursuant to the "section 4(1-1/2)" exemption. Under
this exemption, where the sale of securities does not amount to a distribution
(i.e., a public offering under Section 4(2) of the Securities Act of 1933),
restricted securities or control securities may be resold in private
transactions in reliance upon Section 4(1), regardless of the amount of
securities sold and the period of time during which seller had held the
securities.

Mr. Poulsen's transfer of FFB's shares fall within the "section 4(1-1/2)"
exemption because such transfers were private and thus did not amount to a
distribution, or public offering under Section 4(2). Generally, the sale of
securities is regarded as private when the purchasers are "able to fend for
themselves." SEC v. Ralston Purina Co., 346 U.S. 119 (1953). More specifically,
a sale will be regarded as private when (i) the number of persons acquiring such
securities is small; (ii) the persons acquiring such securities are
sophisticated; (iii) the persons acquiring such securities had access to basic
information relevant to the decision to purchase the securities being offered;
and, (iv) the persons acquiring such shares had the necessary investment intent.

In this case, Mr. Poulsen transferred his shares to ten (10) transferees. Such
transferees were sophisticated in that they were capable of evaluating the risks
associated with the transaction. In addition, information about FFB was made
available to the transferees at the time of the transactions. Please note that
the SB-2 had not been formulated at the time such transfers took place. Eight
out of the ten transferees relationship to the company have been noted in the
SB-2 as being either directors, employees, licensees or contractors to the
company. The other two transferees were spouses of persons related to the
company. As such all transferees had access to company and financial
information. Furthermore, such transferees had the necessary investment intent
when they accepted the transfer of the shares.

Because the transfer of the shares by Mr. Poulsen did not amount to a
distribution, the transactions are exempt from registration under the Securities
Act.

Very truly yours,

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