October 19, 2018

Eric D. Tanzberger
Chief Financial Officer
Service Corporation International
1929 Allen Parkway
Houston, Texas 77019

       Re: Service Corporation International
           Form 10-K for the Year ended December 31, 2017
           Filed February 14, 2018
           Form 10-Q for the Quarter ended June 30, 2018
           Filed July 31, 2018
           File No. 001-06402

Dear Mr. Tanzberger:

       We have reviewed your September 28, 2018 response to our comment letter
and have the
following comment. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

      After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
September 4, 2018 letter.

Form 10-Q For the quarterly period ended June 30, 2018

2. Summary of Significant Accounting Policies
Funeral and Cemetery Operations, page 10

1.    Regarding your response to comment four, we note with respect to
personalized marker
      merchandise sold on a preneed contract, you recognize revenue upon
delivery to the third
      party storage facility or installation of the merchandise at the
cemetery. Please clarify for
      us, for revenue recognition purposes, if you consider control of the
merchandise to have
      been transferred prior to completion of marker engraving and/or final
delivery and
 Eric D. Tanzberger
Service Corporation International
October 19, 2018
Page 2
         installation of a fully engraved product at the cemetery. If so,
please explain to us your
         basis for this policy under ASC 606, including how you considered any
remaining
         performance obligations with respect to the personalized marker
merchandise such as
         custodial or storage services, final engraving and installation at the
time of need.
        You may contact Joseph M. Kempf, Senior Staff Accountant, at
202-551-3352, or Robert
S. Littlepage, Accountant Branch Chief, at 202-551-3361, if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Attorney
Advisor, at 202-551-3415, or Kathleen Krebs, Special Counsel, at 202-551-3350,
with any other
questions.



FirstName LastNameEric D. Tanzberger                           Sincerely,
Comapany NameService Corporation International
                                                               Division of
Corporation Finance
October 19, 2018 Page 2                                        Office of
Telecommunications
FirstName LastName