[SCI Letterhead]

October 17, 2006

Via EDGAR

Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549-0404
Attn: William Bennett

Re:	Service Corporation International (the “Company”)
	Form S-4, as amended, Registration No. 333-132617
	(the “Registration Statement”)

Ladies and Gentlemen:

          With respect to the Registration Statement, we acknowledge and understand our responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended. We also acknowledge that (i) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

          Pursuant to Rule 461(a) under the Securities Act, we hereby request that the effective date for the Registration Statement be accelerated so that it will become effective at 12:00 Noon EST, on Thursday, October 19, 2006, or as soon thereafter as practicable.

Very truly yours,

/s/ Eric D. Tanzberger
Eric D. Tanzberger
Senior Vice President and
Chief Financial Officer
 

cc:	Via Fax: (202) 772-9205 William Bennett
	Securities and Exchange Commission
	Division of Corporation Finance
	100 F Street N.E.
	Washington, D.C. 20549-0404
	Via Fax: (713) 223-3717 J. Eric Johnson
	Locke Liddell & Sapp LLP
	600 Travis Street, Suite 3500
	Houston, Texas 77002