SecProbe.io

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 sgc20250520_corresp.htm

 A NASDAQ Listed Company: SGC

 May 20, 2025

 Securities and Exchange Commission

 Division of Corporation Finance

 Washington, D.C. 20549

 Re:

 Superior Group of Companies, Inc.

 Registration Statement on Form S-3

 Filed on May 13, 2025

 File No. 333-287224

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 5:00 pm Eastern Time on May 22, 2025, or as soon thereafter as is practicable.

 Very truly yours,

 Superior Group of Companies, Inc.

 By : /s/ Jordan Alpert

 Name: Jordan Alpert

 Title: Chief Legal Officer

 Superior Group of Companies | 200 Central Ave, Suite 2000 | St. Petersburg, FL 33701

 Direct: 727-803-7166 | Fax: 727-803-2686 | jalpert@superiorgroupofcompanies.com

 Authorized House Counsel; member of the New York Bar only

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 19, 2025

Michael Benstock
Chief Executive Officer
SUPERIOR GROUP OF COMPANIES, INC.
200 Central Avenue, Suite 2000
St. Petersburg, FL 33701

 Re: SUPERIOR GROUP OF COMPANIES, INC.
 Registration Statement on Form S-3
 Filed on May 13, 2025
 File No. 333-287224
Dear Michael Benstock:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Sarah Sidwell at 202-551-4733 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Roland Chase
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
December 29, 2020
Andrew D. Demott, Jr.
Chief Financial Officer
Superior Group of Companies, Inc.
10055 Seminole Boulevard
Seminole, Florida 33772-2539
Re:Superior Group of Companies, Inc.
Form 10-K for the Year Ended December 31, 2019
Filed February 20, 2020
File No. 001-05869
Dear Mr. Demott:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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	sgc20201216_corresp.htm

December 16, 2020

Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

			Attn:

			Ernest Greene

			John Cash

			Re:

			Superior Group of Companies, Inc.

			Form 10-K for the Year Ended December 31, 2019

			Filed February 20, 2020

			File No. 001-05869

Dear Messrs. Greene and Cash:

By letter dated December 9, 2020, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided a comment on the annual report on Form 10-K for the year ended December 31, 2019 (the “10-K”) filed with the Commission by Superior Group of Companies, Inc. (the “Company”) on February 20, 2020.

This letter responds to such comment. Capitalized terms used but not defined herein have the meaning ascribed to them in the 10-K.

			1.

			We refer to your disclosure of “shipments” which has been defined as a non-GAAP measure. However, based on your description of shipments, it appears that it may be more akin to a financial metric, intended to convey the dollar value of shipments sent to your customers each period, than a non-GAAP measure. Please review the guidance set forth in SEC Release No. 33-10751 and advise. If our understanding is correct, please revise to comply with the disclosure guidance, specifically to provide a more robust statement indicating the reasons why the metric provides useful information to investors and a statement indicating how management uses the metric in managing or monitoring the performance of the business. If our understanding of shipments is incorrect, please explain and tell us how you considered the guidance found in Question 100.04 of the non-GAAP Compliance and Disclosure Interpretations.

Response: We acknowledge the Staff’s comment. After a detailed review of the definition of non-GAAP financial measure and related guidance from the Staff, we concur that shipments as used in the 10-K is akin to a financial metric and does not represent a non-GAAP financial measure (“NGFM”). The intent behind the use of the shipments metric in the Company’s disclosure was to provide investors with a measurement of customer demand affecting its Uniform and Related Products segment. Additionally, management uses the shipments metric to evaluate the performance of the Company’s Uniform and Related Products segment from period to period.

Direct: 727-803-7135 | Fax: 727-803-2641 | ademott@superiorgroupofcompanies.com

We note that SEC Release 33-10751 (the “Release”) lists the disclosure that the Commission generally expects companies to provide when using financial metrics that do not fall within the definition of NGFM in their Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”). This disclosure includes (1) a clear definition of the metric and how it is calculated; (2) a statement indicating the reasons why the metric provides useful information to investors; and (3) a statement indicating how management uses the metric in managing or monitoring the performance of the business. The Release adds that companies should also consider whether there are estimates or assumptions underlying the metric or its calculation, and whether disclosure of such items is necessary for the metric not to be materially misleading.

The Company respectfully asserts that the disclosure it has provided in the 10-K complies with the Commission’s expectations articulated in the Release. First, the disclosure includes a clear definition of the metric (“net sales excluding, if applicable, net sales recorded with respect to contracts with customers in which there is an enforceable right to the payment for goods with no alternative use in advance of the transfer of these goods to our customers”) as well as a reconciliation table that shows how the metric is calculated for the periods presented. Second, the disclosure explains why the metric provides useful information to investors, by stating that shipments, “as a supplemental performance measure, tracks customer demand more closely” than net sales, because net sales, which are recorded when the Company receives the goods from its suppliers rather than at the time it transfers them to its customers “are affected by changes in the Company’s purchasing patterns that may not be directly aligned with customer demand.” Third, the disclosure states that shipments represents a primary metric by which Company management evaluates customer demand. As the Company did not use estimates or assumptions in calculating the metric that would be considered to have a material effect on investors’ understanding of the metric, no such estimates or assumptions were disclosed.

The Company proposes to remove shipments from its future periodic reports, as the relevance of the shipments metric as a supplemental performance measure has decreased, and management expects that, beginning with its results of operations for the full year ended December 31, 2020, the shipments metric will no longer be necessary to an investor’s understanding of the Company’s results of operations. In this context, the Company notes that it has provided the shipments metric in its periodic reports beginning with the quarterly report on Form 10-Q for the quarter ended March 31, 2019 and ending with the quarterly report on Form 10-Q for the quarter ended September 30, 2020 (collectively, the “Periodic Reports”). The following table shows, in $ thousands, for each quarter covered by the Periodic Reports, the difference between net sales and shipments. The decreasing relevance of the metric is demonstrated by the decline in the difference, as a dollar amount and particularly as a percentage of net sales.

2

			Net Sales

			Shipments

			Difference

			Difference as a Percentage of Net Sales

			For the Three Months Ended:

			September 30, 2020

			$
			73,234

			$
			73,113

			$
			121

			0.2
			%

			June 30, 2020

			75,842

			77,916

			(2,074
			)

			-2.7
			%

			March 31, 2020

			60,102

			59,809

			293

			0.5
			%

			December 31, 2019

			63,151

			64,968

			(1,817
			)

			-2.9
			%

			September 30, 2019

			54,979

			60,891

			(5,912
			)

			-10.8
			%

			June 30, 2019

			60,745

			64,261

			(3,516
			)

			-5.8
			%

			March 31, 2019

			58,679

			60,390

			(1,711
			)

			-2.9
			%

The Company acknowledges that it and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff.

Should you have any questions, please do not hesitate to contact the undersigned.

			Sincerely,

			/s/ Andrew D. Demott, Jr.

			Andrew D. Demott, Jr.

			Chief Financial Officer

			Cc:

			Jordan M. Alpert, General Counsel, Superior Group of Companies, Inc.

			Roland S. Chase, Hill, Ward & Henderson, P.A.

3

United States securities and exchange commission logo
December 9, 2020
Andrew D. Demott, Jr.
Chief Financial Officer
Superior Group of Companies, Inc.
10055 Seminole Boulevard
Seminole , Florida 33772-2539
Re:Superior Group of Companies, Inc.
Form 10-K for the Year Ended December 31, 2019
Filed February 20, 2020
File No. 001-05869
Dear Mr. Demott:
            We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Year Ended December 31, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Shipments (Non-GAAP Financial Measure), page 24
1.We refer to your disclosure of “shipments” which has been defined as a non-GAAP
measure.  However, based on your description of shipments, it appears that it may be
more akin to a financial metric, intended to convey the dollar value of shipments sent to
your customers each period, than a non-GAAP measure.  Please review the guidance set
forth in SEC Release No. 33-10751 and advise.  If our understanding is correct, please
revise to comply with the disclosure guidance, specifically to provide a more robust
statement indicating the reasons why the metric provides useful information to investors
and a statement indicating how management uses the metric in managing or monitoring
the performance of the business.  If our understanding of shipments is incorrect, please
explain and tell us how you considered the guidance found in Question 100.04 of the non-
GAAP Compliance and Disclosure Interpretations.

 FirstName LastNameAndrew D. Demott, Jr.
 Comapany NameSuperior Group of Companies, Inc.
 December 9, 2020 Page 2
 FirstName LastName
Andrew D. Demott, Jr.
Superior Group of Companies, Inc.
December 9, 2020
Page 2
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Ernest Greene, Staff Accountant at 202-551-3733 or John Cash,
Accounting Branch Chief at  202-551-3768 if you have questions regarding comments on the
financial statements and related matters.  Please contact Sherry Haywood, Staff Attorney at  202-
551-3345 or Jay Ingram, Legal Branch Chief at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

January 13, 2011
 Mr. Michael Benstock Chief Executive Officer Superior Uniform Group, Inc. 10055 Seminole Blvd.
Seminole, FL 33772

Re: Superior Uniform Group, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2009
Filed February 26, 2010
 File No. 001-05869

Dear Mr. Benstock:
We have completed our review of your fili ngs and do not have any further comments at
this time.
Sincerely,

John Reynolds Assistant Director
cc: Via fax:  (727) 803-9623

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Correspondence

 Andrew D. Demott, Jr.

Executive Vice President, CFO

 January 7, 2011

 John Reynolds

 Division of Corporation Finance

U. S. Securities and Exchange Commission

 450
Fifth Street, N.W.

 Washington, D. C. 20549

RE:

Superior Uniform Group, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2009

Filed February 26, 2010

File No. 001-05869

 Dear Mr. Reynolds:

 I am in receipt of your comment letter dated January 6, 2011, addressed to Michael Benstock Chief Executive Officer of Superior Uniform
Group, Inc. (“Superior” or the “Company”) in which you requested that we file Exhibits 4.1, 4.2, 4.3 and 4.4 in their entirety with our next periodic report.

 We will file these Exhibits in their entirety in our 10-K for the year ended December 31, 2010. This response is being submitted in electronic form on EDGAR.

Please feel free to contact me at (727) 803-7135 should you have any additional questions.

 Very truly yours,

 SUPERIOR UNIFORM GROUP, INC.

/s/ Andrew D. Demott, Jr.

 Andrew D. Demott,
Jr.

 Executive Vice President & CFO

 AD/jp

 10055 Seminole Blvd. Seminole, FL 33772

Direct: 727-803-7135 Fax: 727-803-2641 ademott@superioruniformgroup.com

A NASDAQ Listed Company: SGC

January 6, 2011
 Mr. Michael Benstock Chief Executive Officer Superior Uniform Group, Inc. 10055 Seminole Blvd. Seminole, FL 33772
Re: Superior Uniform Group, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2009
Filed February 26, 2010
 File No. 001-05869

Dear Mr. Benstock:
 We have reviewed your filing and your letter dated December 20, 2010 and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2009

 Exhibits

1. We reissue comment four of our letter dated December 15, 2010.  Please confirm that
you will file exhibits 4.1, 4.2, 4.3, and 4.4 in their entirety with your next periodic report.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 You may contact Blaise Rhodes at (202)  551-3774 or Brian Bhandari, Accounting
Branch Chief, at (202) 551-3390 if you have que stions regarding comments on the financial

Michael Benstock Superior Uniform Group, Inc. January 6, 2011 Page 2

statements and related matters.  Please cont act Shehzad Niazi at ( 202) 551-3121 or Pamela
Howell, Special Counsel, at (202) 551-3357 with any other questions.
 Sincerely,

John Reynolds Assistant Director

CORRESP
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Correspondence

 Andrew D. Demott, Jr.

 Executive Vice President, CFO

 December 20, 2010

John Reynolds

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D. C. 20549

RE:
Superior Uniform Group, Inc.

 Form 10-K for the Fiscal Year Ended

 December 31, 2009

 Filed February 26, 2010

 File No. 001-05869

 Schedule 14A

Filed March 15, 2010

Dear Mr. Reynolds:

 I am in receipt of
your comment letter dated December 15, 2010, addressed to Michael Benstock Chief Executive Officer of Superior Uniform Group, Inc. (“Superior” or the “Company”) in which you requested certain supplemental information
regarding the Company’s Management’s Discussion and Analysis of Financial Condition and Results of Operations and the Schedule 14A for Superior. For your convenience, I have numbered the responses to correspond to the comment number as
outlined in your letter. For those items indicating that we will provide the requested disclosure in the future, we will begin including these disclosures in our 10-K for the year ended December 31, 2010. This response is being submitted in
electronic form on EDGAR.

 Response 1.

 We will provide the requested disclosures in future filings.

 Response 2.

We will provide the requested disclosures in future filings.

 Response 3.

 The advance to our supplier in Haiti for $1.3 million relates to purchases of
raw materials for the supplier.

 10055 Seminole Blvd. Seminole, FL 33772

Direct: 727-803-7135 Fax: 727-803-2641 ademott@superioruniformgroup.com

A NASDAQ Listed Company: SGC

 John Reynolds

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 As the finished goods are shipped to us, we deduct the value of the raw materials from the payment for
the finished goods. We have collected the outstanding balance from the December 31, 2009 balance and have issued additional raw materials to the supplier of $3.3 million during 2010. As of November 30, 2010, we have a receivable balance
from the Haiti supplier of $1.3 million. As of December 31, 2009 the total receivables from our suppliers were $1.4 million. We will provide the requested disclosures in future filings.

 Response 4.

 We acknowledge that certain exhibits and or schedules associated with the
referenced exhibits were inadvertently not included with the filings. However, we believe that all pertinent terms of the missing schedules were adequately summarized within the disclosures of our financial statements. Additionally, all of the
reference agreements in your question are now expired and have been replaced with a new loan agreement with a new financial institution. The new loan agreements were filed in their entirety as Exhibits 10.1 and 10.2 to our June 30, 2010
Quarterly Report on Form 10-Q. If you still believe we should go back and file the additional schedules to our expired credit agreements, we will do so. Finally, we will be certain to include the complete documents in any future exhibits that we
file.

 Response 5.

 We have
provided our draft disclosure that we will include in future filings below.

 The following biographies summarize the experiences,
qualifications, attributes and skills that qualify each of our nominees to serve as directors of the Company.

 Gerald M.
Benstock is the Chairman of the Board of Directors of the Company. Mr. Benstock has served in this position since October 24, 2003. Prior to October 24, 2003, he also served as Chief Executive Officer of the Company. Prior to
May 1, 1992, Mr. Benstock served as President of the Company. Mr. Benstock also has served as a Director of the Company since 1951. Mr. Benstock’s vast experience with the Company is the reason for his nomination for
re-election.

 Michael Benstock has served as Chief Executive Officer of the Company since October 24, 2003.
Mr. Benstock previously served as Co-President of the Company beginning May 1, 1992. Prior to such date, Mr. Benstock served as Executive Vice President of the Company. Mr. Benstock has also been a Director of the Company since
1985. He also serves as a director of USAmeriBank, Inc. Mr. Benstock’s vast experience with the Company is the reason for his nomination for re-election.

 Alan D. Schwartz has served as President of the Company since October 24, 2003. Mr. Schwartz previously served as Co-President of the Company beginning May 1, 1992. Prior to such date,
Mr. Schwartz served as Executive Vice President of the Company. Mr. Schwartz has also served as a Director of the Company since 1981. Mr. Schwartz’s vast experience with the Company is the reason for his nomination for
re-election.

 2

 John Reynolds

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 Manuel Gaetan, Ph.D., has been a Director of the Company since November 7, 1991.
Dr. Gaetan has served as President and Chief Executive Officer of MGR Enterprises, LLC since June of 1993. MGR Enterprises provides business consulting primarily in the area of business strategy and marketing. Dr. Gaetan was President of
the Bobbin Group from August of 1995 until September of 1998 and he served as President and C.E.O. of Bobbin Blenheim, Inc. and was Executive Vice President of Blenheim USA from January of 1990 until August of 1995. Bobbin and subsequently Bobbin
Blenheim was responsible for running major exhibits and trade shows associated with the sewn products industry. Additionally, they were responsible for production and distribution of trade publications supporting the sewn products industry. While
President of Bobbin International, Manuel Gaetan was also president of the Bobbin Consulting Group, which provided broad management consulting services to members of the Sewn Products Industry as well as its suppliers. Dr. Gaetan’s long
tenure and significant contributions on the Board of the Company and his extensive experience in the apparel industry are the reasons for his nomination for re-election.

 Sidney Kirschner has been a Director of the Company since September 25, 1996. In January, 2010, Mr. Kirschner joined Raising the Bar as Managing Director of the Consulting Practice for law
firms, accounting firms and professional service firms. Raising the Bar provides executive coaching, primarily in the area of business development. He has been Head of the School at The Alfred and Adele Davis Academy since March 2006. He retired in
August 2004 as Chairman and Chief Executive Officer of Northside Hospital, Inc., positions that he had held since November 1992. Prior thereto, he served as Chairman of the Board, President and Chief Executive Officer of National Service Industries,
Inc. National Service Industries was a conglomerate including operations in the textile rental business. He also currently serves as a director of Crown Crafts, Inc. Mr. Kirschner’s long tenure and significant contributions on the Board of
the Company, and his extensive experience as a chief executive are the reasons for his nomination for re-election.

 Robin M.
Hensley has been a Director of the Company since July 28, 2000. She has served as President and Business Development Coach of Raising the Bar since May 2004. Raising the Bar provides executive coaching, primarily in the area of business
development. Previously, she was President of Personal Construction, LLC from January of 2000 until May 2004. Prior thereto, she was Vice President of Patton Construction from December of 1995 to January 2000. Her background also includes experience
in public accounting with Ernst and Young. Ms. Hensley’s contributions on the Audit Committee, as the chairperson and financial expert, of the Company and her extensive experience in executive coaching are the reasons for her nomination
for re-election.

 Paul Mellini has been a Director of the Company since May 7, 2004. Mr. Mellini has been CEO and
President of Nature Coast Bank in Citrus County, Florida since March 7, 2005. He was Chief Executive Officer and President of Premier Community Bank of Florida and Premier Community Bank of South Florida from January 2002 until August 2004 and
C.E.O. and President of PCB Bancorp Inc. from January 2003 until August 2004. Prior thereto, he was regional president of First Union Bank of the Greater Bay Area from April 1995 to December 2001. Mr. Mellini’s tenure and significant
contributions on the Board of the Company, and his extensive experience as a chief executive are the reasons for his nomination for re-election.

 3

 John Reynolds

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 In connection with responding to your comments, we acknowledge that:

•

 the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the
filing; and

•

 the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of
the United States.

 Please feel free to contact me at (727) 803-7135 should you have any additional questions.

Very truly yours,

SUPERIOR UNIFORM GROUP, INC.

/s/ Andrew D. Demott, Jr.

Andrew D. Demott, Jr.

Executive Vice President & CFO

AD/jp

 4

December 15, 2010
 Mr. Michael Benstock Chief Executive Officer Superior Uniform Group, Inc. 10055 Seminole Blvd. Seminole, FL 33772
Re: Superior Uniform Group, Inc.
 Form 10-K for the Fiscal Year Ended  December 31, 2009
Filed February 26, 2010
 File No. 001-05869  Schedule 14A  Filed March 15, 2010

Dear Mr. Benstock:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended December 31, 2009

 Item 7.  Management’s Discussion and Analysis, page 11

1. The Management’s Discussion and Analysis sec tion is one of the most critical aspects of
your disclosure.  As such, please confirm that in future filings you will revise this section
to provide a more detailed  executive overview to disc uss the events, trends, and
uncertainties that management views as most  critical to your future revenues, financial
position, liquidity, plan of operations, and resu lts of operations, to the extent known and
foreseeable.  To assist you in this rega rd, please refer to the Commission Guidance
Regarding Management’s Discussion and Analys is of Financial Condition and Results of
Operations, Release Nos. 33-8350 (December 19, 2003) at
http://www.sec.gov/rules/interp/ 33-8350.htm.  This guidance is  intended to elicit more

Michael Benstock Superior Uniform Group, Inc. December 15, 2010 Page 2

meaningful disclosure in MD &A in a number of areas, in cluding the overall presentation
and focus of MD&A, with general emphasis on the discussion and analysis of known
trends, demands, commitments, events a nd uncertainties, and specific guidance on
disclosures about liquidity, capital re sources, and critical accounting.
 Operations, page 11

2. Please confirm that in future filings you will provide a more detailed discussion as to the
reason(s) for the results of operations.
 Liquidity and Capital Resources, page 11

3. We note you include advances to suppliers as  a component of your accounts receivable
balance.  We also note at December 31, 2009, you had an advance to a supplier in Haiti of approximately $1.3 million.  Please (i) provi de us with the current status of this
receivable (i.e. were products  received from the supplier subsequently to offset such
advance), (ii) provide us with the total am ount of advances included in your accounts
receivable and (iii) confirm in  future filings you will disclose  the amount of advances to
suppliers included in your accoun ts receivable balance to provide an investor with a
better understanding of your accounts receivable  from customers versus advances to
suppliers.
 Exhibits

4. We note that exhibits 4.1, 4.2, 4.3, and 4.4 are missing exhibits, schedules and/or
attachments.  Please confirm that you will file these exhibits in their entirety with your
next periodic report.
 Schedule 14A filed March 15, 2010

 Management, page 4

5. On page four you present biographic info rmation for your directors and include a
statement that, “[t]ogether, the experience a nd attributes included  below provide the
reasons that these individuals are nominate d for re-election.”  Please note that the
requested disclosure pursuant to revise d Item 401(e) of Regulation S-K requires
disclosure on an individualized basis.  For guidance your attention is directed to
Regulation S-K CDI 116.05.  Pleas e provide us with draft di sclosure and confirm that
you will comply in future filings.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are

Michael Benstock Superior Uniform Group, Inc. December 15, 2010 Page 3

in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Blaise Rhode s at (202) 551-3774 or Brian Bhandari, Accounting Branch
Chief, at (202) 551-3390 if you have questions regarding comments on the financial statements
and related matters.  Please contact Shehzad Ni azi at (202) 551-3121 or Pamela Howell, Special
Counsel, at (202) 551-3357 w ith any other questions.
 Sincerely,

John Reynolds
Assistant Director

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

       DIVISION OF
CORPORATION FINANCE

 Mail Stop 3561

       December 27, 2007
 Mr. Andrew D. Demott, Jr. Senior Vice President, Chief Fi nancial Officer and Treasurer
Superior Uniform Group, Inc. 10055 Seminole Blvd.
Seminole, Florida 33772
  RE: Superior Uniform Group, Inc.
   Form 10-K for Fiscal Year December 31, 2006
Filed March 13, 2007
Form 10-Q for Fiscal Quarter Ended September 30, 2007
  Filed October 25, 2007    File No. 1-5869

Dear Mr. Demott:   We have completed our review of your Form 10-K and related filings and have no
further comments at this time.           S i n c e r e l y ,              William Thompson          B r a n c h  C h i e f

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Response Letter

Andrew D. Demott, Jr.

Sr. Vice President, CFO

 December 4, 2007

 William Thompson

 Division of Corporation Finance

 U.
S. Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D. C. 20549

RE:
Superior Uniform Group, Inc.

 Form 10-K for the
Year Ended December 31, 2006 and Form 10-Q for Fiscal

 Quarter Ended September 30, 2007

 Commission File No. 1-5869-1

 Dear
Mr. Thompson:

 I am in receipt of your comment letter dated November 26, 2007, addressed to Andrew D. Demott, Jr., Chief Financial Officer of
Superior Uniform Group, Inc. (“Superior” or the “Company”) in which you requested certain supplemental information regarding the Company’s Management’s Discussion and Analysis of Financial Condition and Results of
Operations and the Financial Statements of the above-referenced documents for Superior. For your convenience, I have numbered the responses to correspond to the comment number as outlined in your letter. For those items indicating that we will
provide the requested disclosure in the future, we will begin including these disclosures in our 10-K for the year ended December 31, 2007. As you requested, this response is being submitted in electronic form on EDGAR.

 Response 1.

 We will provide the requested disclosures in future
filings.

 Response 2.

 We will provide the requested
disclosures in future filings.

 Response 3.

 We will
provide the requested disclosures in future filings.

 10055 Seminole Blvd. ¨ Seminole, FL 33772-2539 ¨ Phone (727) 803-7135 ¨ Fax (727) 803-2641

 Website:
www.superioruniformgroup.com ¨ e-mail: ademott@sug.biz

 An American Stock Exchange Listed Company

 William Thompson

 Division
of Corporation Finance

 U. S. Securities and Exchange Commission

 The “Total” column shown on page 33 is shown as additional information to show the actual face value of options and SAR’s for each of the line items shown in the table. The amount is calculated by taking the weighted
average exercise price of the underlying instrument and multiplying it by the number of shares related to the underlying instruments for each line on the chart, such as the number of options/SAR’s granted or exercised in the respective period.
We included it to give the reader additional information on the face of the table relative to the total values of the options and SAR’s. However, given the confusion it appears to generate, we will remove this information from the schedule in
future filings.

 The Related Party Options column in this footnote provides the information for options granted to the Chairman of our Board of Directors
as he is the largest shareholder in the company and owns in excess of 10% of our outstanding common shares. The Other Options column includes the information for all other options issued to our employees and outside directors. We will include a
footnote describing the nature of the Related Party Options in future filings.

 Please feel free to contact me at (727) 803-7135 should you have any
additional questions.

 Very truly yours,

 SUPERIOR UNIFORM
GROUP, INC.

/s/ Andrew D. Demott, Jr.

Andrew D. Demott, Jr.

 Sr. Vice President & CFO

 AD/jp

 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

       DIVISION OF
CORPORATION FINANCE

 Mail Stop 3561
       November 26, 2007
 Mr. Andrew D. Demott, Jr. Senior Vice President, Chief Fi nancial Officer and Treasurer
Superior Uniform Group, Inc. 10055 Seminole Blvd.
Seminole, Florida 33772
  RE: Superior Uniform Group, Inc.
   Form 10-K for Fiscal Year Ended December 31, 2006
Filed March 13, 2007
Form 10-Q for Fiscal Quarter Ended September 30, 2007
  Filed October 25, 2007    File No. 1-5869
Dear Mr. Demott:

We have reviewed your response dated November 9, 2007 to our comment letter
dated November 1, 2007 and have the following additional comments.  We think you should revise your disclosures in future filin gs 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 that we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.  Form 10-K for Fiscal Year Ended December 31, 2006

 Item 8. Financial Statements and Supplementary Data, page 18

 Consolidated Statements of Earnings, page 18

 1. We reviewed your response to comment six from our comment letter dated
November 1, 2007 and continue to believe you should revise your future filings to
show a separate line item for material  gains on sale of property, plant and
equipment.  We also continue to be lieve you should disclose the facts and
circumstances leading to the significan t gain on sale of property, plant and
equipment recorded during fiscal year 2005.  Refer to paragraph 47 of SFAS 144
and Rule 5-03(6) of Regulation S-X.  A dditionally, as previo usly indicated, we

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 26, 2007
Page 2
believe you should revise Management’s Discussion & Analysis (“MD&A”) to
discuss in a reasonable amount of deta il and with an appropriate level of
prominence the significant fiscal year 2005 gain and the related impact on your
reported results of operations.  The offse tting impact of the related relocation of
the operations of the disposed distribu tion facility that you discuss in your
response letter should likewise be  discussed in MD&A.

Notes to Consolidated Financial Statements, page 22

Note 1. Summary of Significant Accounting Policies, page 22

d) Revenue Recognition and Allowance for Doubtful Accounts, page 22
 2. We reviewed your response to comment  nine from our comment letter dated
November 1, 2007.  For each period presented, please demonstrate for us that the
activity in your allowance for sales returns is immaterial for disclosure.  In this
regard, for each period presented, please te ll us the balance at the beginning of the
period, the amount charged to expense dur ing the period, deductions from the
allowance during the period, and the balance at the end of the period.  Otherwise,
as previously requested, please revise to  disclose information related to your
provision for sales returns either in Schedule II – Valuation and Qualifying
Accounts or in your audited footnotes.  See Rules 5-04 and 12-09 of Regulation
S-X.
 Note 12. Stock Options, page 33

 3. We reviewed your response to comme nt 11 from our comment letter dated
November 1, 2007 and continue to believe  you should revise your disclosure to
disaggregate stock options from stock a ppreciation rights (SARs) in the tables
since certain information with respect to exercise prices, such as weighted average exercise price and range of exercise prices , would not appear to be applicable to
SARs.  If you believe we are misunders tanding the nature and terms of your
SARs, please advise.  In the separate disclosures with respect to your SARs,
please disclose the number and weighted-average grant date fair value for SARs outstanding at the beginning of the year, t hose outstanding at the end of the year,
and those granted, vested, or forfeited during the year.  Refer to paragraph
A240.b.(2) of SFAS 123(R).  Al so, please further clarify what the “total” column
represents in the table on page 33, or otherwise remove this  information from
your future filings.  Lastly, as previo usly requested, please tell us what the
“related party options” and “other options” columns represent in the table on page
34.

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a letter that keys your

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 26, 2007 Page 3  responses to our comments and provides a ny requested information.  Detailed response
letters greatly facilitate our review.  Pl ease submit your respon se letter on EDGAR.
Please understand that we may have additiona l comments after reviewing your responses
to our comments.
 If you have any questions regarding these comments, please direct them to Adam
Phippen, Staff Accountant, at (202) 551-3336.  In his absence,  direct your questions to
Robyn Manuel at (202) 551-3823.  A ny other questions may be directed to me at (202)
551-3344.

Sincerely,
 William Thompson
Branch Chief

CORRESP
1
filename1.htm

Correspondence Letter

Andrew D. Demott, Jr.

Sr. Vice President, CFO

 November 9, 2007

 William Thompson

 Division of Corporation Finance

 U.
S. Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D. C. 20549

RE:
Superior Uniform Group, Inc.

 Form 10-K for the
Year Ended December 31, 2006 and Form 10-Q for Fiscal

 Quarter Ended September 30, 2007

 Commission File No. 1-5869-1

 Dear Mr. Thompson:

 I am in receipt of your comment letter dated November 1, 2007, addressed to Andrew D. Demott, Jr., Chief Financial Officer of Superior Uniform Group,
Inc. (“Superior” or the “Company”) in which you requested certain supplemental information regarding the Company’s Management’s Discussion and Analysis of Financial Condition and Results of Operations and the Financial
Statements of the above-referenced documents for Superior. For your convenience, I have numbered the responses to correspond to the comment number as outlined in your letter. For those items indicating that we will provide the requested disclosure
in the future, we will begin including these disclosures in our 10-K for the year ended December 31, 2007. As you requested, this response is being submitted in electronic form on EDGAR.

 Response 1.

 We will provide the requested disclosures in future
filings.

 Response 2.

 We will provide the requested
disclosures in future filings.

 Response 3.

 We will
provide the requested disclosures in future filings.

 10055 Seminole Blvd. ¨ Seminole, FL 33772-2539 ¨ Phone (727) 803-7135 ¨ Fax (727) 803-2641

 Website:
www.superioruniformgroup.com ¨ e-mail: ademott@sug.biz

 An American Stock Exchange Listed Company

 William Thompson.

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 Response 4.

 We
will provide the requested disclosures in future filings.

 Response 5.

 We will provide the requested disclosures in future filings.

 Response 6.

 We believe that it would be misleading to the reader of the financial statements if we were to segregate the 2005 gain as a separate line item on the statement of
earnings. While the amount of the gain on sale of the property was significant, the actual net impact on our pre-tax earnings of the sale and the related relocation of the operations from this facility was less than $50,000 and is not considered
material.

 Response 7.

 We will provide the requested
disclosures in future filings.

 Response 8.

 We
currently include all costs associated with manufacturing or acquiring finished goods in cost of goods sold, including the following major categories:

a.
Raw materials

b.
Direct and indirect labor for the manufacturing process

c.
Manufacturing facility costs and related overhead expenses

d.
Inbound freight, receiving and inspection costs

e.
Internal transfer costs

f.
Purchasing department

g.
Outbound freight

 Selling and administrative expenses include all other
operating types of expenses including the following items related to the distribution of products:

a.
Warehouse space and overhead other than manufacturing locations, receiving and inspection departments

b.
Shipping and distribution payroll and payroll related expenses

 We do
include disclosure of the amounts that are included in selling and administrative expenses in Note 1 subparagraph f.

 We will provide the requested
additional disclosures in future filings.

 Response 9.

 The Company records a provision for estimated returns and allowances based upon product shipments each quarter compared to historical experience and current allowance programs. Historically, the amount of the allowance has not been
material. In the event the amount was to become material, we would include the required disclosure in the footnotes to our financial statements.

 2

 William Thompson.

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 Response 10.

 See
Response 8 above for the detail of those items included within selling and administrative expenses. The only shipping and handling costs included in cost of goods sold are those for the actual outbound freight. These amounts are included as required
by current accounting standards and due to the fact that the related freight invoiced to our customers is included in revenues. We segregate the remaining shipping and handling costs into selling and administrative expenses, as this is how
management has historically viewed our customers and related profitability. It allows us to evaluate customers and opportunities based upon the gross profit associated directly with the merchandise and to separately consider the distribution costs
associated with servicing the customers. As indicated in our response to comment number 8, we will revise our future filings to disclose those shipping and handling costs included in selling and administrative expenses.

 Response 11.

 We do not believe that separate tabular disclosure of
our stock appreciation rights is warranted. Stock appreciation rights (“SAR’s”) are granted on the same date as a significant portion of our stock options. The SAR’s are granted with the same term and strike price as the options
granted on that date. Additionally, the SAR’s require settlement by issuance of Company shares for the intrinsic value at the date of exercise. If the Commission disagrees with this conclusion, we will break out the SAR’s separately in the
future. We will include additional disclosure to clarify the information includes SAR’s.

 The “Total” column shown on page 33 is shown as
additional information to show the actual face value of options and SAR’s for each of the line items shown in the table. We believe it gives the reader additional information on the face of the table relative to the total values of the options
and SAR’s. If the Commission believes these are misleading in some way, we can remove the information from the schedule in future filings.

 Based upon
the guidelines within SFAS 128, and based upon the discussion above regarding the requirement that our SAR’s be settled in Company shares, we include the dilutive impact of our SAR’s in the earnings per share calculation consistent with
the treasury stock method utilized for stock options. We will provide the requested additional disclosures in future filings.

 Response 12.

 We will revise the certifications to read exactly as set forth in Item 601(b)(31) of Regulation S-K.

 Response 13.

 We will add the requested disclosures in future
filings.

 3

 William Thompson.

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 In connection with responding to your comments, we acknowledge that:

•

 the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•

 the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United
States.

 Please feel free to contact me at (727) 803-7135 should you have any additional questions.

 Very truly yours,

SUPERIOR UNIFORM GROUP, INC.

 /s/ Andrew D. Demott, Jr.

Andrew D. Demott, Jr.

Sr. Vice President & CFO

 4

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3561

       November 1, 2007

Mr. Andrew D. Demott, Jr.
Senior Vice President, Chief Fi nancial Officer and Treasurer
Superior Uniform Group, Inc.
10055 Seminole Blvd.
Seminole, Florida 33772

  RE: Superior Uniform Group, Inc.
   Form 10-K for Fiscal Year December 31, 2006
Filed March 13, 2007
Form 10-Q for Fiscal Quarter Ended September 30, 2007
  Filed October 25, 2007
   File No. 1-5869

Dear Mr. Demott:

 We have reviewed your filings and have the following comments.  We have limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to  other portions of your docum ents.  Where indicated, we
think you should revise your disclosures in futu re filings 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 provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may or may not raise
additional comments.

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

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 2
Form 10-K for Fiscal Year Ended December 31, 2006

Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations (MD&A), page 12

Operations, page 12

1. In light of the recurring year  over year decreases in your  net sales, please discuss
whether you expect this trend to continue  in the future and why or why not.  We
believe such additional disclo sure is necessary to an unde rstanding of the extent to
which reported financial information is indi cative of future results.  Refer to Item
303(a) of Regulation S-K and SEC Release No. 33-8350.

2. Please revise to explain in a reasonabl e amount of detail the reason(s) for the
significant reduction in your accrual for tax contingenc ies during fiscal year 2005
as such reduction had a 15% effect on reported net income.

Liquidity and Capital Resources, page 13

3. At times your discussion and analysis of financial condition, changes in financial condition and cash flows focuses only on fiscal 2006 and fiscal 2006 as compared
to fiscal 2005.  Please revise to provide  a discussion and analysis of financial
condition, changes in financial condition and cash flows for three year period
covered by the financial statements.  Th e discussion and analysis should address
material year to year changes in financ ial position and cash flows and the reasons
underlying those changes and provide information that is relevant to an understanding of your financial condition and cash flows.  Refer to Item 303(a) of
Regulation S-K and SEC Release No. 33-8350.

4. Please revise your table of  contractual cash obligati ons and commitments to
include estimated interest payments on outstanding debt obligations and amounts
to be funded to cover post-employment be nefits.  Because the table is aimed at
increasing transparency of cash flow, we believe these payments should be
included in the table.  If you choose not to include these payments, please provide
information regarding these cash requirements in a footnote to the table to the extent material.  See Section IV.A and footnote 46 to SEC Release No. 33-8350.

Critical Accounting Policies, page 15

5. Please revise your disclosure to desc ribe the material implications of uncertainties
associated with the methods, assumptions  and estimates underlying your critical
accounting measurements that have had or that you reasonably expect will have a
material impact on financial conditio n and operating performance and on the
comparability of reported information among periods.  Such disclosure should

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 3
supplement, not duplicate, the accounting policies disclosed in the notes to the
financial statements.  In preparing your revised disclosure, please identify those
accounting estimates or assumptions wher e there is a significant amount of
subjectivity involved, the estimates or assu mptions are susceptible to change, and
the impact of the estimates and assu mptions on your financial condition or
operating performance is material.  Discuss, to the extent material, such factors as
how you arrived at each estimate, how accurate the estimate/assumption has been in the past, how much the estimate/assumption has changed in the past and whether the estimate/assumption is reasonably likely to change in the future.  We
would expect you to provide quantitative as  well as qualitativ e disclosure when
quantitative information is reasonably availa ble and to provide greater insight into
the quality and variabilit y of information regardi ng financial condition and
operating performance.  The quantitative di sclosure should incl ude, to the extent
material, information about your provisions and allowances for doubtful accounts receivable, sales returns a nd excess and obsolete inventor ies, self-insurance stop
loss coverage and reserves, impairment lo sses, stock-based compensation, income
tax contingencies and pension and post re tirement benefit costs.  Also, since
critical accounting estimates and assumpti ons are based on matters that are highly
uncertain, you should analyze and disclose their specific sensitivity to change, based on other outcomes that are reasonabl y likely to occur and would have a
material effect.  For example, if reasonabl y likely changes in the long-term rate of
return used in accounting for your pension plan would have a material effect on
your financial condition or operating performance, the impact that could result
given the range of reasonably likely out comes should be disclosed and quantified.
Please refer to Item 303(a)(3)(ii) of Re gulation S-K as well as the Commission’s
Guidance Regarding Management’s Disc ussion and Analysis of Financial
Condition and Results of Operations, SEC Release No. 33-8350, issued December
19, 2003 and available on our website at
www.sec.gov .

Item 8. Financial Statements and Supplementary Data, page 18

Consolidated Statements of Earnings, page 18

6. Please revise to show a separate line ite m for material gains on sale of property,
plant and equipment.  Also disclose th e facts and circumstances leading to the
significant gain on sale of property, plan t and equipment recorded during fiscal
year 2005.  Refer to paragraph 47 of SFAS 144 and Rule 5-03(b)(6) of Regulation S-X.  Additionally, given that over 40% of your reported earnings before income
taxes in fiscal year 2005 related to these gains, pl ease revise your MD&A to
discuss in a reasonable amount of deta il and with an appropriate level of
prominence the significant fiscal year 2005 gains and the related impact on your reported results of operations.

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 4
Consolidated Statements of Shareholders’ Equity, page 20

7. Please disclose reclassification adjustment s and the amount of income tax expense
or benefit allocated to each component  of other comprehensive income on the
face of the statements of shareholders’ e quity or in the notes to the financial
statements.  Refer to paragraphs 20 and 25 of SFAS 130.

Notes to Consolidated Financial Statements, page 22

Note 1. Summary of Significant Accounting Policies, page 22

8. Please disclose the types of expenses th at you include in the cost of goods sold
line item and the types of expenses that you include in the selling and administrative expenses line item.  In  doing so, please disclose specifically
whether you include purchasing and r eceiving costs, inspection costs,
warehousing costs, internal transfer cost s and the other costs of your distribution
network in cost of goods sold.  With the exception of ware housing costs, if you
currently exclude a signifi cant portion of these costs from cost of goods sold,
please provide cautionary disclosure in MD&A that your gross margins may not
be comparable to others, since some entitie s include all of the costs related to their
distribution network in cost of goods sold  and others exclude a portion of them
from gross margin, including them instead in operating expense line items.  To
the extent the excluded costs are material  to your operating results, quantify these
amounts in MD&A.  If you determine th at these amounts are immaterial for
disclosure, please provide us with your qualitative and quantitat ive assessment of
materiality for all periods presented.

d) Revenue Recognition and Allowance for Doubtful Accounts, page 22

9. To the extent material please revise to  disclose information related to your
provision for sales returns in Schedule II – Valuation and Qualifying Accounts.
Alternatively, you may include this inform ation in your footnotes.  See Rules 5-04
and 12-09 of Regulation S-X.

f) Shipping and Handling Fees and Costs, page 22

10. Please tell us and revise your disclosure  to clarify the natu re of the “other”
shipping and handling costs included in sel ling and administrative expenses.  Also
explain to us why these particular shi pping and handling costs are classified as
selling and administrative expenses, while  the remainder of your shipping and
handling costs is classified as  cost of goods sold.

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 5

Note 12.  Stock Options, page 33

11. Please revise your disclosure to di saggregate stock options from stock
appreciation rights (SARs) in  the tables, as information with respect to exercise
prices, such as weighted average exercise prices and the range of exercise prices,
would not appear to be app licable to stock appreciation rights.  Refer to paragraph
A240.f. of SFAS 123(R).  In the separate disclosures with re spect to your SARs,
please disclose the number and weighted-average grant date fair value for SARs outstanding at the beginning of the year, t hose outstanding at the end of the year,
and those granted, vested, or forfeited during the year.  Refer to paragraph
A240.b.(2) of SFAS 123(R).  In addition, pleas e tell us and revise  to clarify what
the “total” column represents in the tabl e on page 33 and what the “related party
options” and “other options” columns repres ent in the table on page 34.  Lastly,
with reference to SFAS 128, please tell us  and disclose how you treat SARs in
your calculation of earnings per share.

Exhibits 31.1 and 31.2

12. Please revise your certifications to read ex actly as set forth in Item 601(b)(31) of
Regulation S-K.  In particular, replace “a nnual report” with “report.”  Also revise
to include the parenthetical language that is required in paragraphs 4.d. and 5.

Form 10-Q for Fiscal Quarter Ended September 30, 2007

13. Please address the comment s above as applicable.

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
responses to our comments.  Please su bmit your response letter on EDGAR.

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filings to be certain that the filings include all information required under the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Mr. Andrew D. Demott, Jr.
Superior Uniform Group, Inc. November 1, 2007
Page 6
In connection with responding to our co mments, please provide, in writing, a
statement from the company acknowledging that:

• the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

• staff comments or changes to disclosu re in response to staff comments do
not foreclose the Commission from ta king any action with respect to the
filings; and

• the company may not assert staff comments as a defense in any
proceeding initiated by the Commissi on or any person under the federal
securities laws of the United States.

  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

If you have any questions regarding these comments, please direct them to Adam
Phippen, Staff Accountant, at (202) 551-3336.  In his absence,  direct your questions to
Robyn Manuel at (202) 551-3823.  A ny other questions may be directed to me at (202)
551-3344.

Sincerely,

 William Thompson
Branch Chief

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

										May 05, 2005

By Facsimile and U.S. Mail

Mr. Andrew D. Demott, Jr.
Chief Financial Officer
Superior Uniform Group, Inc.
10055 Seminole Blvd.
Seminole, Florida 33772

	Re:	Forms 10-K for the year ended December 31, 2004
      Filed March 16, 2005 and April 28, 2005
      File No. 1-5869

Dear Mr. Demott:

	We have completed our review of your Forms 10-K and related
filings and have no further comments at this time.

								Sincerely,

									George F. Ohsiek, Jr.
									Branch Chief
??

??

??

??

March 22, 2005
Page 1

</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

Correspondence

 Andrew D. Demott, Jr.

 Sr. Vice President,
CFO

 May 3, 2005

 George F. Ohsiek, Jr.

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D. C. 20549

RE:
Superior Uniform Group, Inc.

 Form 10-K for the
Year Ended December 31, 2004

 Commission File No. 1-5869-1

 Dear Mr. Ohsiek:

 I am in receipt of your comment letter dated May 3, 2005, addressed to Andrew D. Demott, Jr., Chief Financial Officer of Superior Uniform Group, Inc.
(“Superior” or the “Company”). We will make the change you requested relative to the classification of cash flows associated with the Company’s prepaid pension costs. We will incorporate this change beginning with our 10-Q
for the quarter ended March 31, 2005. As you requested, this response is being submitted in electronic form on EDGAR.

 Please feel free to contact me at (727) 803-7135 should you have any additional questions.

 Very truly yours,

 SUPERIOR UNIFORM GROUP, INC.

 /s/ Andrew D. Demott, Jr.

Andrew D. Demott, Jr.

Sr. Vice President & CFO

 AD/jp

 10055 Seminole Blvd. ¨ Seminole, FL 33772-2539
¨ Phone (727) 803-7135 ¨ Fax (727) 803-2641

 Website:
www.superioruniformgroup.com ¨ e-mail: ademott@sug.biz

 An American Stock Exchange Listed Company

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

										May 3, 2005

By Facsimile and U.S. Mail

Mr. Andrew D. Demott, Jr.
Chief Financial Officer
Superior Uniform Group, Inc.
10055 Seminole Blvd.
Seminole, Florida 33772

		RE:	Form 10-K for the year ended December 31, 2004
			Filed March 16, 2005 and April 28, 2005

Dear Mr. Demott:

	We have reviewed your responses in your letter dated March
14,
2005 and have the following additional comment.

	We welcome any questions you may have about our comment or on
any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

Consolidated Statement of Cash Flows, page 15

1. We read your response to comment 3.  We do not believe that the
prepaid pension benefit costs that are recorded in your other
assets
line item meet the criteria described in paragraph 17(a) or (b) of
SFAS 95.  Specifically, the debt or equity instruments to which
the
funds are ultimately expended are not recorded in your financial
statements.  Given that defined benefit pension costs are a
component
of your overall compensation package, please revise future filings
to
record the amounts in operating activities.

	As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please ensure the response letter provides any requested
supplemental
information.  Please file your response letter on EDGAR.  Please
understand that we may have additional comments after reviewing
your
response to our comment.

	If you have any questions regarding these comments, please
direct them to Anthony Watson, Staff Accountant, at (202) 551-3318
or, in his absence, to me at (202) 551-3843.

							Sincerely,

							George F. Ohsiek, Jr.
							Branch Chief
??

??

??

??

May 3, 2005
Page 2

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SEC Letter

 April 20, 2005

 George F.
Ohsiek, Jr.

 Division of Corporation Finance

 U. S. Securities
and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D.
C. 20549

RE:

 SuperiorUniform Group, Inc.

 Form 10-K for the Year Ended December 31, 2004

 Commission File No. 1-5869-1

 Dear Mr. Ohsiek:

 I am in receipt of your comment letter dated April 6, 2005, addressed to Andrew D. Demott,
Jr., Chief Financial Officer of Superior Uniform Group, Inc. (“Superior” or the “Company”) in which you requested certain supplemental information regarding the Company’s Management’s Discussion and Analysis of
Financial Condition and Results of Operations and the Financial Statements of the above-referenced document for Superior. For your convenience, I have numbered the responses to correspond to the comment number as outlined in your letter. For those
items indicating that we will provide the requested disclosure in the future, we will begin including these disclosures in our 10-Q for the quarter ended March 31, 2005 or in our 10-K for the year ended December 31, 2005, as appropriate. As you
requested, this response is being submitted in electronic form on EDGAR.

 Response 1.

 The Company duly notes and acknowledges this comment.

 Response 2.

 We will provide the
requested information in future filings where more than one item contributes to a material change in financial statement line items.

 Response 3.

 Other Assets consists primarily of the following items:

a.

Cash Surrender Value of Life Insurance $4.2 million

b.

Prepaid pension benefit costs $2.9 million

 We have included these items in investing activities in the statement of cash flows as discussed in FASB 95 “Statement of Cash Flows” based upon the fact that
the funds expended for these items are to ultimately acquire debt and equity instruments of other entities.

 George F. Ohsiek, Jr.

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 We have provided separate disclosure of any items that exceed the 5% of total assets threshold. No items within the other assets caption
exceed this 5% threshold.

 We will provide the requested disclosure in
M,D&A in future filings.

 Response 4.

 We currently include all costs associated with manufacturing or acquiring finished goods in cost of goods sold including, the following major categories:

a.

Raw materials

b.

Direct and indirect labor for the manufacturing process

c.

Manufacturing facility costs and related overhead expenses

d.

Inbound freight, receiving and inspection costs

e.

Internal transfer costs

f.

Purchasing department

g.

Outbound freight

 Selling and administrative expenses include all other operating types of expenses including the following items related to the distribution of products:

a.

Warehouse space and overhead other than manufacturing locations, receiving and inspection departments

b.

Shipping and distribution payroll and payroll related expenses

 We will provide the requested disclosures in future filings.

 Response 5.

 The Company has very limited involvement with advertising
expense. Total advertising costs for 2004, 2003 and 2002 were approximately $160,000, $145,000, and $ 135,000, respectively. The Company expenses advertising costs as incurred. We will provide the requested disclosure in future filings.

 Response 6.

 Approximately 95% of the Company’s revenues come from sales of uniforms and career apparel that are the primary products sold under each of the Company’s brands of any significance. These products are
generally of a similar nature and the same products may be sold to a variety of customers in different markets. We believe that 95% of our product revenue comes from products of a very similar nature and as such; we do not believe the standard calls
for further breakdown of revenues of our products.

 Response 7.

 The Company records revenue as products are shipped and title passes. We will revise the disclosure as requested in future filings.

 2

 George F. Ohsiek, Jr.

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 Response 8.

 The Company records a
provision for estimated returns and allowances based upon product shipments each quarter compared to historical experience and current allowance programs. We will provide the requested disclosure in the footnotes to our financial statements in
future filings.

 Response 9.

 We will provide the requested disclosure in future filings.

 Response 10.

 The Company has never issued cash to an employee to
settle an outstanding stock option. The Company did acquire 13,250 combined shares of common stock acquired by its chairman and chief financial officer during 2004. The shares were acquired by the officers by option exercise on November 1, 2004 and
were reacquired by the Company on November 8, 2004. This is the only transaction of this nature that the Company has ever entered into. The total compensation expense associated with this transaction was approximately $70,000.

 Response 11.

 We will provide the following additional disclosure in future filings as requested:

 The Company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial
reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. Internal control over financial reporting includes those policies and procedures that:

•

pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Company;

•

provide reasonable assurance that transactions are recorded, as necessary, to permit preparation of financial statements in accordance with generally accepted accounting principles,
and that receipts and expenditures of the Company are being made only in accordance with authorizations of management and directors of the Company; and

•

provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the Company’s assets that could have a material effect
on the financial statements.

 Because of its
inherent limitations, internal control over financial reporting may not prevent or detect misstatements.

 3

 George F. Ohsiek, Jr.

 Division of Corporation Finance

 U. S. Securities and Exchange Commission

 In connection with responding to your comments, we acknowledge that:

•

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•

the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Please feel free to contact me at (727) 803-7135 should you have
any additional questions.

 Very truly yours,

 SUPERIOR UNIFORM GROUP, INC.

/s/ Andrew D. Demott, Jr.

 Andrew D. Demott, Jr.

 Sr. Vice President & CFO

 AD/jp

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