VIA EDGAR

Mr. Rufus Decker
Accounting Branch Chief
Mail Stop 7010
Securities and Exchange Commission
Division of Corporation Finance
100 F St., N. E.
Washington, DC  20549-7010

August 25, 2009

Re: ENGlobal Corporation ("ENGlobal" or "the Company")
Form 10-K for the fiscal year ended December 31, 2008
Form 10-Q for the period ended March 31, 2009 and June 30, 2009
Schedule 14A filed on April 30, 2009
File No. 1-14217

Dear Mr. Decker:

With respect to the above-captioned filing, we enclose ENGlobal's responses to
the comments posed by the staff of the Securities and Exchange Commission set
forth in your comment letter dated August 12, 2009. As requested, our responses
are keyed numerically to the comments received from the Securities and Exchange
Commission.

1.   You disclose on page 28 that the loss of a major client relationship
     resulted in a $5.3 million (6.8%) reduction in revenues for the six months
     ended June 30, 2009 and a $3 million (9.0%) reduction in revenues for the
     three months ended June 30, 2009. In light of the loss of this major client
     relationship, please tell us if you performed an interim goodwill
     impairment analysis for the engineering segment as of June 30, 2009. If you
     did not perform an interim goodwill impairment analysis, please tell us how
     you considered paragraph 28 of SFAS 142 in determining that the analysis
     was not necessary.

          We did not perform a goodwill impairment analysis as of June 30, 2009
          and do not believe that such an analysis was required by paragraph 28
          of SFAS 142. The statement that there was a "loss of a major client
          relationship" referred only to the field services work being provided
          to that client. In fact, the client in question continues to be a
          significant client for ENGlobal in other areas, and is one of our top
          five revenue-producing clients.

          The cancellation of the field services work that the Engineering
          segment was performing for this client is the type of event that
          occurs regularly in the ordinary course of our business. Our project
          mix changes constantly and, subject to factors such as macroeconomic
          conditions, projects that are cancelled or completed are continually
          replaced with new projects from existing and new clients.



In responding to the comments received from the Securities and Exchange
Commission, ENGlobal acknowledges that:

          ENGlobal is responsible for the adequacy and accuracy of the
          disclosure in their filings;

          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;

          ENGlobal may not assert staff comments as a defense in any proceeding
          initiated by the Commission or any person under the federal securities
          laws of the United States; and

          The Division of Enforcement has access to all information provided to
          the staff of the Division of Corporation Finance.

If you have any questions regarding these comments, please direct them to Robert
W. Raiford at (409) 840-2578.

ENGlobal Corporation

/s/ Robert W. Raiford

Robert W. Raiford
Chief Financial Officer

Cc:   Division of Corporation Finance
      Mr. William Coskey, Chairman
      and Chief Executive Officer, ENGlobal
      Mr. Randy Hale, Audit Committee Chairman
      ENGlobal Board of Directors