Mail Stop 6010
Via Facsimile and U.S. Mail


November 18, 2005



Mr. Roy T. K. Thung
President and Chief Executive Officer
American Independence Corp.
485 Madison Avenue
New York, New York 10022

      Re:      American Independence Corp.
       Form 10-K for Fiscal Year Ended December 31, 2004
	            File No. 001-05270

Dear Mr. Thung:

      We have reviewed your October 11, 2005 response to our
September 27, 2005 letter and have the following comment. In our
comment, we 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Management`s Discussion and Analysis

Outlook, page 24

1. Please refer to prior comment two. We understand that business
production originates with your MGUs, is underwritten by IHC and
then
ceded to you. Your proposed new disclosure does not discuss or
quantify the key factors underlying the significant increase in
business produced by your MGUs and underwritten by IHC in 2004 and
the corresponding 59% increase in your assumed premiums and only
states that an increase in 2005 premiums earned similar to that in
2004 is not expected. This disclosure does not appear to
facilitate
investors` determination of the likelihood that your past
performance
is indicative of future performance. Please explain to us and
quantify, in disclosure-type format, the key factors and trends
underlying the increase in 2004 MGU production, IHC`s revenue
growth
and your assumed premiums and provide a more specific discussion
and
quantification of the impact of these key factors and related
trends
on your expected revenues and operating results.

*    *    *    *
            Please respond to the comment within 10 business days
or
tell us when you will provide us with a response.  Detailed
letters
greatly facilitate our review.  Please file your letter on EDGAR
under the form type label CORRESP.

           You may contact Frank Wyman, Staff Accountant, at 202-
551-
3660 or Don Abbott, Senior Staff Accountant, at 202-551-3608, if
you
have questions regarding the comments.  In this regard, do not
hesitate to contact me, at (202) 551-3679.

								Sincerely,


								Jim B. Rosenberg
							Senior Assistant Chief
      Accountant
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Mr. Roy T. K. Thung
American Independence Corp.
November 18, 2005
Page 2