SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

      September 13, 2007

Mr. Steven P. Wyandt Chief Executive Officer and Chief Financial Officer Nitches, Inc. 10280 Camino Santa Fe San Diego, California 92121
 Re: Nitches, Inc.
  Forms 10-K and 10-K/A for Fisc al Year Ended August 31, 2006
Filed December 14, 2006 and January 31, 2007
Forms 10-Q and 10-Q/A for Fiscal Quarters Ended No vember 30, 2006,
February 28, 2007  and May 31, 2007
File No. 0-13851

Dear Mr. Wyandt:
We have reviewed your response dated August 21, 2007 to our comment letter
dated May 29, 2007 and have the following a dditional comments.  Where indicated, we
think you should revise your docum ents in response to these comments.  If you disagree,
we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please provide a wr itten response to our comments.  Please be as detailed
as necessary in your explanation.  In some of our comments, we may ask you to provide
us with information so that we may bette r understand your disclosure.  After reviewing
this information, we may raise additional comments.  Form 10-Q for Fiscal Quarter Ended February 28, 2006

 Item 1.  Financial Statements

 Note 9.  Stock-Based Compensation

 1. We have reviewed your response to co mment two in our letter dated May 29,
2007.  Please show us exactly how you computed share-based compensation expense for each of the first three quarters of fiscal 2007 as it remains unclear how your computation complies with SFAS 123R.  In particular, it appears you

Mr. Wyandt
Nitches, Inc.
September 13, 2007 Page 2 of 3
have only recorded compensation expense to the extent of the immediate grant
date vesting of each of the option awards whereas we would expect you to record additional expense associated with the c ontinued vesting of these awards during
the periods.  Moreover, it remains unclear how you considered expected
forfeitures in computing share-based comp ensation costs.  Please advise.  Finally,
as previously requested, please tell us a nd disclose the requisite service periods
and vesting terms of the stock option aw ards.  In filing your amended Forms 10-Q
for the periods ended November 30, 2006, February 28, 2007 and May 31, 2007, please ensure you comply with the disc losure requirements in SFAS 154 with
respect to the restatement of previously issued financial statements.
 Form 10-Q/A for Fiscal Quarter Ended May 31, 2007

 Item 1.  Financial Statements

 Note 15.  Pending Restatements

 2. In your response to comment one in our letter dated May 29, 2007, you take the position that you will not restate your historic al financial statements for the errors
you have identified in your income tax accounting due to materiality considerations.  This position appears to be inconsistent with the presentation and
disclosure in the filing.  Based on our teleconference on September 5, 2007, we
understand that you intend to file an amendment to restate your financial
statements to conform to the position ta ken in your correspondence.  In the
amendment, please ensure you comply with  the disclosure requirements of SFAS
154 with respect to the restatement.   Al so disclose in a reasonable amount of
detail the nature and amount of the income tax accounting error(s) included in previously issued financial statements  and your basis for not restating those
financial statements to correct such errors.

*    *    *    *

As appropriate, please amend your filings and  respond to these comments within
10 business days or tell us when you will provid e us with a response.  Please furnish a
letter that keys your respons es to our comments and provide s any requested information.
Detailed response letters greatly facilitate our  review.  Please submit your response letter
on EDGAR.  Please understand that we may have additional comments after reviewing
your amendment and responses to our comments.

Mr. Wyandt
Nitches, Inc. September 13, 2007 Page 3 of 3
You may contact Staff Accountant Robyn Manuel at (202) 551-3823 if you have
questions regarding comments on the financial statements and related matters.  Please
contact me at (202) 551-3344 with any other questions.
         S i n c e r e l y ,             William Thompson         B r a n c h  C h i e f