July 22, 2005

Mail Stop 4561


Wayne A. Schellhammer
President and Chief Executive Officer
American Caresource Holdings, Inc.
8080 Tri-Star Drive
Irving, Texas 75063


Re:	American Caresource Holdings, Inc.
      Amendment No. 1 to Registration Statement on Form SB-2
Filed on July 7, 2005
	File No. 333-122820

Dear Mr. Schellhammer:

      We have reviewed your filing and have the following
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
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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Cover Page
1. We note your response to Comment 4.  In the third full
paragraph
on the Cover Page you state that the "selling shareholder is not
obligated to sell its shares at any fixed price and has indicated
that it intends to sell its shares from time to time only if and
when
a public market for ACS common stock is established at prices
prevailing in such market. We currently estimate that our common
stock will have a value of $.41 per share upon the effective date
of
this prospectus, which price will likely change if and when a
public
market in the shares of Common Stock is established."  Please
revise
this disclosure to state the fixed price (or price range) at which
your selling shareholder will sell its shares  prior to your
shares
being quoted on the OTC Bulletin Board and thereafter at
prevailing
market prices, or privately negotiated prices.  Refer to Item 501
of
Regulation S-B and Item 16 to Schedule A.

Security Ownership of Certain Beneficial Owners and Management and
Selling Shareholders
2. Please revise the first two sentences to remove the implication
that this prospectus registers the distribution of shares to
Patient
InfoSystems ("PATY").  We note from your disclosure on the cover
page
and in the Distribution section that the 1,000,000 shares being
registered for resale are currently held by PATY.  Therefore, it
is
not appropriate to register the distribution of these shares to
PATY.

Financial Statements

3. As a follow-up to the conference call on July 22, 2005, please
expand your critical accounting policies and intangible asset
footnote to discuss your attrition data and any significant trends
related to your provider contracts.  This discussion should be
updated in future filings as material changes occur.  Further,
please
provide an expanded analysis of the annual impairment test you
will
perform.  You should address items considered in your impairment
analysis such as contract terminations, cash flow projections,
etc.


Other

      As appropriate, please amend your registration statement in
response to these comments.  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 supplemental 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 will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.


	You may contact Howard Efron, Accountant, at (202) 551-3439
or
Cicely Luckey, Accounting Branch Chief, at (202) 551-3413 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact David Roberts, Staff Attorney, at (202)
551-
3856 or the undersigned at (202) 551-3694 with any other
questions.


      Sincerely,



      Owen Pinkerton
      Senior Counsel


cc:	Jeffrey A Baumel, Esq. (via facsimile)
      McCarter & English, LLP




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Wayne A. Schellhammer
American Caresource Holdings, Inc
July 22, 2005
Page 1