Room 4561 						 March 16, 2006 John Birbeck President and Chief Executive Officer CTI Group (Holdings), Inc. 333 North Alabama Street, Suite 240 Indianapolis, IN 46204 Re:	CTI Group (Holdings), Inc. 	Form 10-KSB for Fiscal Year Ended December 31, 2004 	File No. 0-10560 Dear Mr. Birbeck: We have completed our review of your Form 10-KSB and have no further comments at this time. Sincerely, Kathleen Collins Accounting Branch Chief ?? ?? ?? ?? Mr. Michael S. Gilliland Sabre Holding Corporation February 28, 2006 Page 2