COVER 4 filename4.txt [GREENBERG TRAURIG, LLP LETTERHEAD] John C. Kirkland Tel. 310.586.7786 Fax 310.586.0286 KirklandJ@gtlaw.com February 18, 2005 BY EDGAR Securities and Exchange Commission 450 5th Street, N.W. Judiciary Plaza Washington, D.C. 20549 Re: Hythiam, Inc. CIK: 000112353 Post-Effective Amendment to Form S-1 on Form S-3 Ladies and Gentlemen: We are transmitting herewith a post-effective amendment on Form S-3 to a registration statement on Form S-1, for filing on behalf of our client Hythiam, Inc. (the "Company"), relating to the resale of shares of common stock of the Company by the listed selling shareholders. Please feel free to contact me by e-mail at KirklandJ@gtlaw.com or by telephone at 310.586.7786 or with any questions or to discuss this matter. Sincerely, /s/ JOHN C. KIRKLAND John C. Kirkland JCK:mb