SecProbe.io

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December 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 December 22, 2005 letter and have the following responses:

General
-------

     1. When discussing the possible section 5 violation, please make clear the
activities of Fort Street Equity as an underwriter in the distribution of these
shares on behalf of the company and the potential liability resulting as an
underwriter in this offering.

ANSWER: We have disclosed the possible Section 5 violation in the Risk Factors
and MD&A section. In both sections, we have disclosed Fort Street Equity's
activities as an underwriter in the distribution of these shares on behalf of
the Company and the potential liability resulting as an underwriter in this
offering.

Risk Factors page 7
--------------------

     2. Risk factor 2 should clearly discuss in the subheading and in the risk
factor narrative the potential rescission liability as a result of the possible
section 5 violation, The narrative should make clear the total dollar amount of
possible rescission liability.

ANSWER: In Amendment No. 8 to Form SB-2, we have revised the Risk Factor
subheading and body of the risk factor to discuss the potential rescission
liability, specifically, the total dollar amount of possible rescission
liability.

Management's Discussion and Analysis, page 17
---------------------------------------------

     3. Please add back the results of operations for the year ended June 30,
2005 as compared to the same period in 2004.

ANSWER: In Amendment No. 8 to Form SB-2, we have updated the disclosure as
requested.

     4. The possible rescission liability should be discussed in the beginning
of the MD&A section and should be discussed in greater detail. Focus on the
potential liability to the company and discuss the impact this could have upon
your liquidity and capital resources.

ANSWER: In Amendment No. 8 to Form SB-2, we have updated the disclosure as
requested.

     5. Update the disclosure regarding loans due to (from) related parties as
of the most recent financial statements.

ANSWER: In Amendment No. 7 to Form SB-2, this has already been disclosed in the
"Loans Due To (From) Related Parties" table in the prospectus at page 66.

<PAGE>

Financial Statements
--------------------
Options Granted to Fort Street Equity
-------------------------------------

     6. You have represented that the $10,000 cash payment made by Fort Street
Equity is the fair value of the option. This results in the payment of Fort
Street of $0.005 per share. We also note that Fort Street has sold approximately
600,000 of these options to other parties at a price range of $0.17 - $0.30 per
share. Given the difference in these amounts, please explain to us how you
determined that the $10,000 payment represents fair, value. Provide us with,
your supporting analysis.

ANSWER: Discussion and Disclosure of Events and Transactions
        ----------------------------------------------------

On November 10, 2003, Fit For Business (Australia) Pty Limited, an Australian
private company ("FFB Australia") and party to the reverse merger transaction
effected under a Share Exchange Agreement (the "Exchange Agreement") on
September 14, 2004, with Fit For Business International, Inc., a Nevada
corporation and formerly Patient Data Corporation ("FFBI"), entered into an
agreement with Fort Street Equity, Inc. ("Fort Street") whereby Fort Street
would assist FFB Australia with the following: (i) the identification of a
corporation validly organized in the United States with which FFB Australia
could realize a reverse merger; and (ii) the completion and filing of a
Registration Statement on Form SB-2 with the SEC for the purpose of raising
capital from the issuance of common stock in the public markets of up to $4.5
million. The agreement between Fort Street and FFB Australia provided that the
estimated cost of completing a reverse merger with a U.S. corporation would be
between $265,000 and $290,000. Further, the agreement provided for the payment
of a retainer fee by FFB Australia to Fort Street against costs and expenses of
the reverse merger of $100,000. Additional amounts were to be paid as the
reverse merger process moved ahead. However, the agreement between FFB Australia
and Fort Street did not specifically provide for or indicate fees or commissions
payable to Fort Street for its services as part of the reverse merger
transaction; only a range of funds to be paid (as indicated above) to Fort
Street for the completion of the reverse merger, where the costs of the reverse
merger would be born by Fort Street. The initial capital formation activity
conducted by FFBI and Fort Street was not successful due to the fact that the
organization and completion of a reverse merger with a validly organized
corporation in the United States could not be effected. FFBI and Fort Street
initiated a second capital formation activity that resulted in the Exchange
Agreement between FFB Australia and FFBI, as described above, and the current
activity to file a Registration Statement on Form SB-2 with the SEC.

In June 2004, as part of the second capital formation activity and prior to the
effective date of the Exchange Agreement, Mr. Mitchell Stough, Managing Member
of Fort Street ("Stough"), and Mr. Kevin Murray, a business consultant from
Toronto, Canada ("Murray"), contacted Mr. C. Anthony Ferracone, the then
President and Sole Director of FFBI ("Ferracone"), for the purpose of arranging
the reverse merger. Both Stough and Murray previously had been in contact and
discussions with the President of FFB Australia, Mr. Mark A. Poulsen
("Poulsen"), before the effective date of the agreement with Fort Street
(November 10, 2003), and, through individual letter agreements (the "Letter
Agreements") dated September 1, 2003, personally executed between the parties
(considered outside the framework of the operations of FFB Australia), Stough
and Murray agreed to perform financial advisory services for Poulsen in
connection with the planned FFB Australia reverse merger transaction for fees in
the form of shares of common stock to be transferred to them, or their nominees,
from the common stock issued to Poulsen from a successful reverse merger
transaction valued at .75% of the value of any common stock acquired by Poulsen
from such reverse merger. Following the completion of the Exchange Agreement,
Poulsen transferred, in satisfaction of the Letter Agreements with Stough and
Murray, 112,500 shares of common stock received by Poulsen under the Exchange
Agreement to Kellie Stough, the wife of Stough, as his nominee; and, 112,500
shares of common stock received by Poulsen under the Exchange Agreement to
Louise Murray, the wife of Murray, as his nominee.

<PAGE>

As part of the reverse merger process between FFB Australia and FFBI, and prior
to the execution of the Exchange Agreement, FFBI, Fort Street, Ferracone, Stough
and Murray completed the following transactions:

      1.      Subsequent to July 25, 2004, Ferracone, for consulting services
              rendered in connection with the reverse merger, was paid $10,000
              in cash. As FFBI was essentially a dormant shell at the time with
              virtually no assets or operations, the funds were paid to
              Ferracone by FFBI from the proceeds of the sale of 2,000,000
              options to purchase common stock sold to Fort Street (see below).

      2.      On July 25, 2004, FFBI, in order to meet its obligation for
              consulting services related to the reverse merger to Ferracone,
              granted and sold 2,000,000 stock options to purchase a like number
              of shares of common stock to Fort Street for $10,000. The sale by
              FFBI of the 2,000,000 options to purchase common stock to Fort
              Street was not considered as "compensation for services" by Fort
              Street, but as a financing transaction by FFBI whereby funds were
              raised to pay Ferracone in connection with the completion of the
              reverse merger transaction.

      3.      On August 6, 2004, Fort Street purchased 914,000 shares of common
              stock of FFBI from an existing shareholder(s) for an undisclosed
              amount.

      4.      On August 6, 2004, Murray purchased 750,000 shares of common stock
              of FFBI from an existing shareholder(s) for an undisclosed amount.

Prior to the sale of 2,000,000 options to purchase the same number of shares of
common stock to Fort Street for $10,000, or $.005 per share, the only
transaction recorded on the books of account of FFBI was the issuance of
5,000,000 shares of common stock on May 30, 2001, to former officers and
directors for services rendered in connection with the formation of FFBI. The
value of the services rendered by the former officers and directors was $5,000,
or $.001 per share, the par value of the common stock of FFBI.

Supporting Analysis of Value of Stock Options
---------------------------------------------

The following illustrates the analysis of the determination of value of the
stock options sold to Fort Street:

              Value of services provided by Ferracone                  $10,000
                                                                       =======
              Par value of common stock                                $.001
                                                                       =====
              Incremental value ($.001 each year) - years 2001-2004    $.004
                                                                       =====
              Determined value - Total par value + incremental value   $.005
                                                                       =====
              Number of options to be granted at determined value
              ($10,000 divided by $.005)                               2,000,000
                                                                       =========

Value of Stock Options Sold by Fort Street

Subsequent to the purchase of the stock options by Fort Street, FFBI converted
its convertible promissory notes in two transactions as follows:

      1.      On September 20, 2004, 420,000 shares of common stock were issued
              in connection with the call and conversion of convertible notes
              with a unit value of 42 units for $140,000, or $0.33 per share.

      2.      On September 29, 2004, 450,000 shares of common stock were issued
              in connection with the call and conversion of the remaining
              convertible notes with a unit value of 45 units for $225,000, or
              $0.50 per share.

<PAGE>

Under the terms of the Option Agreement, the exercise price of the options is
the higher of $0.50 per share or the average trading price of FFBI's common
stock over the preceding ten business days prior to exercise of the options,
less a discount of 40 percent. Since no trading value has been established for
FFBI's common stock, and the only historical values established for FFBI's
common stock result from the conversion of promissory notes (as indicated
above), Fort Street has applied the option price formula to its sales of
approximately 600,000 options as follows:

           Historical range of prices per share of common stock    $0.33 - $0.50
           (from transactions involving conversion of notes)

           Discount per option pricing formula                          40%

           Price range generally used by Fort Street               $0.17 - $0.30

     7. Tell us whether the option was intended to reflect compensation to Fort
Street for services rendered or to be rendered, or for financing purposes.

ANSWER: The stock options to purchase 2,000,000 shares of common stock sold by
FFBI to Fort Street for $10,000 were not intended to reflect compensation to
Fort Street for services rendered or to be rendered, but, as explained above,
were for financing purposes in connection with the payment for services rendered
by Ferracone.

     8. We note the language in paragraph 4 of the Stock Option Agreement that
discusses the non-assignability of the option. At the time the option was
granted, did you intend for Fort Street to sell the options to other parties and
lend the sale proceeds to you? If not, tell us when this arrangement was agreed
to by Fort Street and Fit For Business.

ANSWER: In the Private Placement Subscription & Receipt for Shares Agreement
executed on July 24, 2004, which was the predecessor agreement to the Stock
Option Agreement executed on July 25, 2004, under the Section "Representations
and Acknowledgments", paragraph (a), it states:

         "(a) The undersigned represents that he/his company is acquiring the
         options for investment for his own account and not with a view to
         resell or otherwise distribute such options; that he does not intend to
         divide his participation with others or to resell or otherwise dispose
         of all of any part of such options unless and until he determines at
         some future date that changed circumstances not now in contemplation
         make such disposition advisable. . ."

This paragraph differs from paragraph 4 of the Stock Option Agreement as to
non-assignability of the options without the consent of FFBI. However, at the
time the options were sold to Fort Street, it was not the intent of FFBI or Fort
Street that such options would be re-sold, or that the proceeds from such sales
would be loaned to FFBI under the terms of promissory notes. The decision to
enter into such transactions between Fort Street and FFBI was made in May 2005,
when it became apparent that the timeframe for completion of the Registration
Statement on Form SB-2 with the SEC would need to be extended, and additional
resources would be needed to complete such registration process and sustain the
operations of FFBI.

     9. Tell us more about the parties, other than the Wendts, who purchased the
options from Fort Street.

ANSWER: Further information relating to the parties who purchased the options
from Frost Street Equity is as follows:

Ralston Superannuation Fund, a related party. This superannuation fund has as
Trustees Prins Ralston and his spouse Leanne Ralston. Prins Ralston is the Chief
Operating Officer and Senior Vice President of FFBI. Prins and Leanne Ralston
are Australian Citizens and reside in Brisbane, Australia.

Bruce Gilling, an unrelated party. Mr. Gilling is a self employed consultant who
is a British citizen currently residing in Florida, USA. Mr. Gilling is a
personal acquaintance of Mr. Poulsen.

<PAGE>

Therese Mulherin, a related party. Ms. Mulherin is a part-time employee of FFBI.
Ms. Mulherin is an Australian citizen residing in Brisbane, Australia.

Mark Hoey, a related party. Mr. Hoey is a common share stockholder of FFBI prior
to acquiring the Options. Mr. Hoey is employed as an Airline Pilot by Cathay
Pacific Airlines. Mr. Hoey is an Australian citizen currently residing in Hong
Kong.

Kelly Superannuation Fund is an unrelated party. This superannuation fund has
as Trustees Michael Kelly and his spouse Angelique Kelly. Ms. Kelly is an
accountant and personal acquaintance of Ms. Sandra Wendt. Michael and Angelique
Kelly are Australian Citizens and reside in Brisbane, Australia.

Keith Appleby, an unrelated party. Mr. Appleby is a professional investor who is
an Australian citizen and resident of Brisbane, Australia. Mr. Appleby is a
personal acquaintance of Mr. Poulsen.

None of the option holders had any prior relationship with Michell Stough or
Fort Street Equity before