Mail Stop 3-8


										April 6, 2005

By Facsimile and U.S. Mail


Mr. Andrew D. Demott, Jr.
Chief Financial Officer
Superior Uniform Group, Inc.
10055 Seminole Blvd.
Seminole, Florida 33772


		RE:	Form 10-K, for the year ended December 31, 2004
			Filed March 16, 2005


Dear Mr. Demott:

	We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
future
filings 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 supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
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 on 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 YEAR ENDED DECEMBER 31, 2004

General

1. Where a comment below requests additional disclosures or other
revisions to be made, these revisions should be included in your
future filings, as applicable.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Operations, page 7

2. Please quantify those changes where two or more factors
contributed to material changes in financial statement line items
between periods.  For instance, where you discuss the various
reasons
for changes in your net sales, it would be helpful if you
quantified
the amount of sales generated from UniVogue subsequent to your
acquisition versus changes in demand from your existing customers.
This would provide the reader with a better understanding of the
change and the extent to which each factor contributed to the
overall
change.  See Item 303(a) of Regulation S-K and SEC Release No. 33-
8350.

Consolidated Statement of Cash Flows, page 15

3. Please tell us the nature of the "Other asset" line item and
your
GAAP basis for including amounts in your investing activities.  We
assume that a significant portion of the "Other asset" line item
relates to the cash surrender value of split-dollar life insurance
policies.  To the extent any item included in "Other assets" on
your
balance sheet exceeds 5% of total assets amounts should be
separately
stated.  See Rule 5-02.17 of Regulation S-X.  Notwithstanding the
company`s balance sheet presentation, you should discuss the
nature
of the cash payments made for all periods presented in your
discussion of liquidity in MD&A.

Notes to Consolidated Financial Statements

General

4. Please tell us more about and disclose, in more detail, the
types
of expenses that you include in the cost of goods sold line item
and
the types of expenses that you include in the selling and
administrative expenses line item.  Specifically address whether
you
include inbound freight charges, purchasing and receiving costs,
inspection costs, warehousing costs, internal transfer costs, and
the
other costs of your distribution network in the cost of goods sold
line item.  If you currently exclude a portion of these costs from
cost of goods sold, please disclose:
* in a footnote the line items that these excluded costs are
included
in and the amounts included in each line item for each period
presented, and
* in MD&A that your gross margins may not be comparable to those
of
other entities, since some entities include all of the costs
related
to their distribution network in cost of sales and others exclude
a
portion of them from gross margin, including them instead in a
line
item, such as selling and administrative expenses.

5. Please disclose your policy for advertising expenses and the
amount reported in your statement of earnings for each year
presented.  See paragraph 49 of SOP 93-7.

6. We note that you sell several types of products based on your
discussion in Item 1. Business and the product line references on
your website. Please provide the product line revenue disclosures
required by paragraph 37 of SFAS 131.  In particular, we assume
that
would require revenue disclosures for each period presented for
the
following:

- Healthcare
- Food Service
- Entertainment
- Retail
- Hospitality
- Transportation
- Public Safety
- Industrial
- Cleanroom
- Corp Apparel

Please confirm to us that you will provide these required
disclosures
in future filings.  If you believe that other product categories
are
more appropriate, please advise.

Note 1.  Summary of Significant Accounting Policies

d) Revenue Recognition and Allowance for Doubtful Accounts, page
16

7. Please revise your policy to clarify when title and risk of
loss
pass to your customers under the terms of your sales agreements
(for
example, FOB shipping point).

8. Please disclose your accounting policy for sales returns and
allowances.  Revise future filings to disclose the information
related to your sales returns and allowances and other valuation
accounts in Schedule II -Valuation and Qualifying Accounts.
Alternatively, you may include this information in your footnotes.
See Rules 5-04 and 12-09 of Regulation S-X.

Note 10.  Quarterly Results for 2003 and 2004

9. Please disclose gross profit (net sales less cost and expenses
associated directly with or allocated to products sold) in your
selected quarterly financial data.  See Item 302(a)(1) of
Regulation
S-K.



Note 17.  Stock Repurchase Plan, page 27

10. Please disclose your accounting policy for cash paid to an
employee to settle an outstanding stock option, to settle an
earlier
grant of a stock award within six months after vesting, and to
repurchase shares within six months after exercise of an option or
issuance.  Please also disclose the timing, nature and terms of
each
such transaction, including the amount of compensation expense
recorded in each period presented.  For each settlement and
repurchase transaction that is with an employee where you do not
think that FIN 44 applies to that transaction, please demonstrate
for
us why not.  See paragraphs 65 and 66 of FIN 44.

Item 9A.  Controls and Procedures, page 9A

11. In future filings please ensure you include the full
definition
of disclosure controls and procedures in your disclosure.  See
Release 33-8238 Section II.D for further guidance.


	As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please provide us with a response letter that keys your responses
to
our comments and provides any requested supplemental information.
Please file your response letter on EDGAR.  Please understand that
we
may have additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.


	If you have any questions regarding these comments, please
direct them to Anthony Watson, Staff Accountant, at (202) 942-7781
or, in his absence, to me at (202) 942-2905.

							Sincerely,



							George F. Ohsiek, Jr.
							Branch Chief
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April 6, 2005
Page 5