[GREENBERG TRAURIG, LLP LETTERHEAD] John C. Kirkland Tel. 310.586.7786 Fax 310.586.0286 KirklandJ@gtlaw.com September 28, 2005 BY EDGAR Securities and Exchange Commission 450 5th Street, N.W. Judiciary Plaza Washington, D.C. 20549 Re: Hythiam, Inc. CIK: 000112353 Amendment No. 1 to Form S-3 File No. 333-128544 Ladies and Gentlemen: We are transmitting herewith a pre-effective amendment no. 1 to Form S-3 registration statement, for filing on behalf of our client Hythiam, Inc. (the "Company"), relating to the shelf registration of additional shares of common stock of the Company pursuant to Rule 429. Please feel free to contact me by e-mail at KirklandJ@gtlaw.com or by telephone at 310.586.7786 or with any questions or to discuss this matter. Sincerely, /s/ JOHN C. KIRKLAND John C. Kirkland JCK: mb