MEMORANDUM OF RESPONSES

RICK’S CABARET INTERNATIONAL, INC.

FILE NO. 001-13922

SEC Comment Letter dated July 9, 2009

1. In response to the Staff’s comment number 1, we confirm that we will comply with the Staff’s comment in future filings.

2. In response to the Staff’s comment number 2, we confirm that we will comply with the Staff’s comment in future filings.

	RICK'S CABARET INTERNATIONAL, INC.
Date:  July 13, 2009	By:/s/ Eric S. Langan
	Eric S. Langan
	Chief Executive Officer and President

Date:  July 13, 2009	By:/s/ Phillip K. Marshall
	Phillip K. Marshall
	Chief Financial Officer and Principal Accounting Officer