SEC Company Response from NITCHES INC (NICH) (CIK 0000772263) (NICH) — Oct 19, 2006

NITCHES INC (NICH) (CIK 0000772263)
Date: Oct. 19, 2006 · CIK: 0000772263 · Accession: 0001206774-06-002143

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File numbers found in text: 333-136470

Date

October 19, 2006

Author

/s/ Steven P. Wyandt

Form

CORRESP

Company

NITCHES INC (NICH) (CIK 0000772263)

Letter

Re: Nitches Inc.

NITCHES, INC. 10280 Camino Santa Fe San Diego, California 92121

October 19, 2006

VIA EDGAR

Mr. H. Christopher Owings, Assistant Director U. S. Securities and Exchange Commission Division of Corporate Finance One Station Place 701 First Street, N.E. Washington, D.C. 20002

Registration Statement on Form S-1 File No. 333-136470

Mr. Owings:

Pursuant to Rule 461 under the Securities Act of 1933, Nitches, Inc, a California corporation (“Nitches”) hereby requests that the effectiveness of Nitches' Registration Statement on Form S-1 (File No. 333-136470), be accelerated to 9:00 a.m. on Tuesday, October 24, 2006, or as soon thereafter as practicable.

The Registrant acknowledges that:

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve Nitches from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

Nitches may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,
/s/ Steven P. Wyandt

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CORRESP
1
filename1.htm

NITCHES, INC.
10280 Camino Santa
Fe
San Diego, California 92121

October 19, 2006

VIA EDGAR

Mr. H. Christopher Owings, Assistant
Director
U. S. Securities and Exchange Commission
Division of Corporate
Finance
One Station Place
701 First Street, N.E.
Washington, D.C. 20002

Re:     Nitches
Inc.

Registration Statement on Form
S-1
           File No.
333-136470

Mr. Owings:

Pursuant to Rule 461 under the Securities Act of 1933, Nitches, Inc, a
California corporation (“Nitches”) hereby requests that the effectiveness of
Nitches' Registration Statement on Form S-1 (File No. 333-136470), be
accelerated to 9:00 a.m. on Tuesday, October 24, 2006, or as soon thereafter as
practicable.

The Registrant acknowledges that:

  should the Commission or the staff, acting
  pursuant to delegated authority, declare the filing effective, it does not
  foreclose the Commission from taking any action with respect to the
  filing;

  the action of the Commission or the staff, acting pursuant to
  delegated authority, in declaring the filing effective, does not relieve
  Nitches from its full responsibility for the adequacy and accuracy of the
  disclosure in the filing; and

  Nitches may not assert the declaration of effectiveness as a
  defense in any proceeding initiated by the Commission or any person under the
  federal securities laws of the United States.

    Sincerely,

    /s/ Steven P. Wyandt

        Chief Executive
      Officer

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