-----BEGIN PRIVACY-ENHANCED MESSAGE-----
Proc-Type: 2001,MIC-CLEAR
Originator-Name: webmaster@www.sec.gov
Originator-Key-Asymmetric:
 MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen
 TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB
MIC-Info: RSA-MD5,RSA,
 H0cKsXkBm5Gy2Qq0tEx+72qh7YHs3eB4ZZyQj52SD0BZpQwE5ssNCMcvSEAzLYKb
 fB9zL7/a9tJHbHHgqiX5tg==

<SEC-DOCUMENT>0000000000-05-053953.txt : 20060824
<SEC-HEADER>0000000000-05-053953.hdr.sgml : 20060824
<ACCEPTANCE-DATETIME>20051024122525
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-05-053953
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20051024

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			CRDENTIA CORP
		CENTRAL INDEX KEY:			0001073857
		STANDARD INDUSTRIAL CLASSIFICATION:	SERVICES-EMPLOYMENT AGENCIES [7361]
		IRS NUMBER:				760585701
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		14114 DALLAS PARKWAY
		STREET 2:		SUITE 600
		CITY:			DALLAS
		STATE:			TX
		ZIP:			75254
		BUSINESS PHONE:		972-850-0780

	MAIL ADDRESS:	
		STREET 1:		14114 DALLAS PARKWAY
		STREET 2:		SUITE 600
		CITY:			DALLAS
		STATE:			TX
		ZIP:			75254

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	LIFEN INC
		DATE OF NAME CHANGE:	20001115

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	DIGIVISION INTERNATIONAL LTD
		DATE OF NAME CHANGE:	20001005
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>




      October 17, 2005

Mail Stop 4561

James D. Durham
Chief Executive Officer
Crdentia Corp.
14114 Dallas Parkway, Suite 600
Dallas, TX 75254

      Re:	Crdentia Corp.
      Schedule 14A
File No. 0-31152
October 6, 2005

Dear Mr. Durham:

      We have limited our review of your filing to those issues we
have addressed in our comments. Where indicated, we think you
should
make changes in response to these comments.  If you disagree, we
will
consider your explanation as to why our comment is inapplicable.
Please be as detailed as necessary in your explanation.  Please be
as
detailed as necessary in your explanation.  In some of our
comments,
we may ask you to provide us with information so we may better
understand your disclosure.  After reviewing this information, we
may
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.

Proposal No. 1

Payment for Fractional Shares, page 8

1. Please explain how the "fair market value" of your shares will
be
determined.  To the extent you do not intend to rely exclusively
on
market price, please explain why.




Proposal No. 4, page 31

Implications of the Amendment, page 32

2. We note that you have proposed amending Mr. Durham`s employment
agreement so that he will receive a bonus in connection with any
sale
of the company.  Please explain why Mr. Durham`s employment
agreement
is being amended in this manner and please disclose whether you
are
currently negotiating for the sale of your company.

Section 16(A) Beneficial Ownership Reporting Compliance, page 33

3. Please revise this section to make it more readable.

	As appropriate, please amend your filing 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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments and the declaration of
effectiveness as defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.
      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.


      You may contact Geoffrey Ossias at 202-551-3404 or me at
202-
551-3780 with any other questions.


Sincerely,



Karen J. Garnett
Assistant Director


cc: 	Kristopher Hanson (via facsimile, 858-523-2811)
??

??

??

??

James D. Durham
Crdentia Corp.
October 17, 2005
Page 1








</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
-----END PRIVACY-ENHANCED MESSAGE-----
