September 4, 2018

Eric D. Tanzberger
Chief Financial Officer
Service Corporation International
1929 Allen Parkway
Houston, Texas 77019

       Re: Service Corporation International
           Form 10-K for the Year ended December 31, 2017
           Filed February 14, 2018
           Form 10-Q for the Quarter ended June 30, 2018
           Filed July 31, 2018
           File No. 001-06402

Dear Mr. Tanzberger:

       We have reviewed your July 27, 2018 response to our comment letter 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

        After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
July 3, 2018 letter.

Form 10-Q for the Quarterly Period Ended June 30, 2018

Condensed Consolidated Statement of Operations, page 5

1.    We note your response to comment 1. In light of the significance of the
amounts
      involved, we continue to believe your income statement presentation
should fully comply
      with Rule 5-03(b) of Regulation S-X.
 Eric D. Tanzberger
Service Corporation International
September 4, 2018
Page 2
2. Summary of Significant Accounting Policies
Funeral and Cemetery Operations, page 10

2.       We note your response to comment 2. Please clarify in your policy
disclosure the nature
         of your travel protection service, and the memorilization merchandise
and personalized
         marker merchandise, pursuant to ASC 606-10-50-12c.
3.       Regarding the sale of cemetery property interment rights, please
clarify in your policy
         note on page 11 if you recognize as revenue that portion of the
proceeds required by state
         law to be paid into perpetual care trust funds.
4.       We note from your response to comment 3 why each individual piece of
merchandise and
         service is considered distinct. Please explain further why they are
distinct within the
         context of the contract. It seems a customer will likely have a view
that they have
         purchased a bundle of integrated goods and services i.e. a funeral,
rather than several
         individual outputs. We refer you to ASC 606-10-25-21.
Insurance-funded preneed contracts, page 11

5.       Please explain to us why it is appropriate to report general agency
commissions as funeral
         revenue or revise.
6.       Consistent with your response to comment 5, please disclose that the
policy holder has
         made a non-binding commitment to assign the benefits of the policy at
the time of need.
         In addition please tell us if, at the time of purchasing the life
insurance contract, the
         customer selects specific merchandise and services or simply a level
of coverage. Also,
         tell us if the life insurance proceeds are paid directly to the
Company, requiring no
         additional action by third parties at the time of need, or is it
necessary for a representative
         acting on behalf of the policyholder to take some additional action in
order for the
         proceeds of the policy to be paid to the Company.


        You may contact Joseph M. Kempf, Senior Staff Accountant, at
202-551-3352 or Robert
S. Littlepage, Accountant Branch Chief, 202-551-3361, if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Attorney
Advisory at 202-551-3415 or Kathleen Krebs, Special Counsel, at 202-551-3350
with any other
questions.



FirstName LastNameEric D. Tanzberger                             Sincerely,
Comapany NameService Corporation International
                                                                 Division of
Corporation Finance
September 4, 2018 Page 2                                         Office of
Telecommunications
FirstName LastName