SecProbe.io

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Mail Stop 6010

								August 30, 2005

Raymond R. Quirk
Chief Executive Officer
Fidelity National Title Group, Inc.
601 Riverside Avenue
Jacksonville, Florida 32204

	Re:	Fidelity National Title Group, Inc.
		Registration Statement on Form S-1, Amendment 1
		Filed August 18, 2005
		File No. 333-126402

Dear Mr. Quirk:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure.  After reviewing this
information,
we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We
look forward to working with you in these respects.  We welcome
any
questions you may have about our comments or any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

FORM S-1

General

1. We note our prior comment 23 and your response.  Please
disclose
the company`s operating margins.  Also, supplementally, explain to
us
the basis for your belief that your margins are among the best in
the
industry.  Did you perform a study?  Is there available data from
one
or more third-party sources which support your contention?  Please
share any such data with us.

The Distribution

No Fractional Shares, page 14

2. Refer to your response to comment 11.  We recognize the
additional
disclosure which does not appear to address the issue of the
expected
sales price related to these shares.  Please revise the disclosure
to
include a discussion of the anticipated sales price per share for
the
fractional shares to be sold.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Critical Accounting Policies

Reserve for Claim Losses, page 23

3. Please refer to your response to our prior comment number 17.
Please disclose the results of the two primary statistical studies
that are developed by your external actuaries.  To the extent that
management modifies the estimate determined in these studies to
arrive
at the actual amount in your financial statements, disclose the
factors that affected the decision to record the estimate at that
amount.

Legal Proceedings, page 47

4. We note your response to comment 26.  Item 103 of Regulation S-
K
requires disclosure of "the relief sought" for each material legal
proceeding.  Therefore, for every lawsuit discussed in this
section,
please disclose the amount of damages demanded.  If no amount has
been
specified for certain cases, so state.

Financial Statements - December 31, 2004

Notes to Combined Financial Statements

B. Acquisitions

Acquisition of Micro General Corporation, page F-15

5. Please refer to your response to our prior comment number 45.
We
note that Micro General is not a subsidiary of the company.
Please
tell us why you included this disclosure, if the financial
information
of this company is not reflected in the consolidated financial
statements.

J. Commitments and Contingencies, pages F-22 - F-24

6. We note your response to our prior comment number 47.  Please
note
that we view the disclosure of the amounts being sought in each
lawsuit as the maximum of a range of potential settlements as
discussed in SFAS 5 with not settlement being the lower end of
that
range.  Please revise your discussion of the amounts being sought
by
the plaintiffs in each of the se actions.  You may want to
disclose
separately the amount of premium refund versus the amount of
damages
sought if you feel it is helpful in understanding the potential
impact
of these legal actions.

Exhibit Index, page II-8

7. Agreements filed pursuant to Item 601(b)(10) of Regulation S-K
are
typically material enough that their principal terms should also
be
discussed in the body of the filing.  Please ensure that you
provide
appropriate disclosure concerning each of these contracts.  In
your
response letter, please list the page numbers where each exhibit
filed
under Item 601(b)(10) is discussed in your filing.

*	*	*

	As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	You may contact Tabatha Akins at (202) 551-3658 or James
Atkinson
at (202) 551-3674 if you have questions regarding comments on the
financial statements and related matters.  Please contact Greg
Belliston at (202) 551-3861, Michael Reedich at (202) 551-3612, or
me
at (202) 551-3715 with any other questions.

								Sincerely,

								Jeffrey Riedler
								Assistant Director

cc:	Robert S. Rachofsky
	LeBoeuf, Lamb, Greene & MacRae LLP
	125 West 55th Street
	New York, NY 10019-5389
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Raymond R. Quirk
Fidelity National Title Group, Inc.
August 30, 2005
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