Mail Stop 3561



							January 20, 2006



Mark Poulsen, Chief Executive Officer
Fit for Business International, Inc.
3155 E. Patrick Lane
Suite 1
Las Vegas, Nevada

		RE:	Fit for Business International, Inc.
			Registration Statement on Form SB-2
			File No. 333-122176
			Amendment Filed: December 30, 2005

Dear Mr. Poulsen:

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

General
1. We reissue our prior comment 1 because your discussion of the
possible section 5 violation does not adequately address Fort
Street
Equity`s role as an underwriter in the distribution of the
securities
on behalf of the company.  Please make clear that Fort Street
Equity
was acting as an underwriter when it sold the securities acquired
from the company to Ralston Superannuation Fund, Bruce Gilling,
Therese Mulherin, Kelly Superannuation Fund, Mark Hoey, Sandra
Wendt,
Keith Appleby, Neil Wendt.

Management`s Discussion and Analysis
2. We reissue a portion of our prior comment 4.  Expand your MD&A
disclosure to include a discussion of how the potential rescission
liability might affect your liquidity and capital resources.

Financial Statements
3. It appears to us that Fort Street, a principal stockholder,
granted the options to third parties and your employees on your
behalf and that you should recognize the applicable compensation
in
your financial statements in accordance with SAB Topic 5.T.  We
note
that you rely upon Fort Street Equity to provide cash to finance
your
operations via the promissory notes.  We also believe that you
would
not be able to obtain financing from another party under the
favorable terms that Fort Street provides due to your status as a
development stage entity with no significant operating history and
weak financial condition.  Accordingly, it appears to us that Fort
Street is a principal stockholder as defined by paragraph 395 of
SFAS
123 based upon its status as your largest source of cash flow,
which
we believe gives it the ability to significantly influence you.
Please revise the financial statements to recognize compensation
for
the options granted by Fort Street Equity and provide all
disclosures
required by paragraphs 45-48 of SFAS 123, as applicable.  For
purposes of determining the fair value of the options granted (and
volatility), please note that you became a public entity upon the
initial filing of the SB-2 in March 2005.
4. Your response to Comment No. 6 suggests that the issuance of
225,000 shares in aggregate to Messrs. Stough and Murray through
certain nominees represents a compensatory transaction entered
into
by Mr. Poulsen on behalf of FFBI.  Please confirm that the
financial
statements bear the appropriate amount of compensation.

Closing Comments

      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 direct your attention to Rules 460 regarding requesting
acceleration of 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 Babette Cooper at (202) 551-3396 if you have
questions regarding comments on the financial statements and
related
matters.  Questions on other
disclosure issues may be directed to Jay Ingram at (202) 551-3397,
or
to Pam Howell, who supervised the review of your filing, at (202)
551-3357.


      Sincerely,



John Reynolds
Assistant Director
Office of Emerging Growth Companies

cc.	Richard Anslow, Esq.
	732-577-1188







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Mark Poulsen
Fit For Business International, Inc.
January 20, 2006
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