December 20, 2005



Mr. Tomas W. Fuller
Chief Financial Officer
VCA Antech, Inc.
12401 West Olympic Boulevard
Los Angeles, California 90064-1022


	Re:	VCA Antech, Inc.
		Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 16, 2005
Form 10-Q for Fiscal Quarters Ended March 31, 2005, June 30, 2005
and
September 30, 2005
      Filed May 9, 2005, August 8, 2005, and November 8, 2005
		File No. 001-16783


Dear Mr. Fuller:

      We have reviewed your filings and have the following
comments.
We have limited our review of your filings to those issues we have
addressed in our 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 10-K for the Fiscal Year Ended December 31, 2004

Note 2. Summary of Significant Accounting Policies, page 52

b. Revenue Recognition, page 53

1. We note your policy of deferring revenue and cost of goods
sold,
in connection with multiple element arrangements, and subsequently
recognizing these amounts "on a straight-line basis over the
periods
in which the maintenance services are being provided."  Please
clarify what these deferred amounts represent and identify the
accounting guidance you are relying upon in support of your
presentation.

s. Mandatorily Redeemable Partnership Interests, page 57

2. We note that you are required to purchase certain partner`s
equity
in the event of their death and that you have calculated the value
of
these liabilities to be $2.1 million and $2.2 million as of
December
31, 2004 and 2003.  Please provide a description of the
methodology
you use to determine the value of these liabilities and explain
why
these amounts have not been accrued.  Specifically address SFAS 5
and
FIN 45 in your response.

Controls and Procedures, page 36

3. You state that there were no "significant changes" in your
"internal controls" and no factors that could "significantly
affect"
these controls subsequent to the date of their evaluation.
However,
Item 308(c) of Regulation S-K requires that you disclose any
change
in the registrant`s "internal control over financial reporting"
identified in connection with the evaluation required by paragraph
(d) of Exchange Act Rules 13a-15 or 15d-15 that occurred during
the
fiscal quarter that has "materially affected, or is reasonably
likely
to materially affect, the registrant`s internal control over
financial reporting."  See also paragraph 4(d) of Regulation S-K,
Item 601, Exhibit 31.  Please revise your disclosure accordingly.
This comment also applies to your Forms 10-Q.

Closing Comments

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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.

	In connection with responding to our comments, 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 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Jennifer Goeken at (202) 551-3721 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3683 with any other
questions.

								Sincerely,



								Jill S. Davis
								Branch Chief

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Mr. Tomas W. Fuller
VCA Antech, Inc.
December 20, 2005
Page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010