SecProbe.io

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

January 31, 2007

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.

    Preliminary Proxy Statement on
      Schedule 14A

    Filed November 7,
      2006

    File No. 0-13851

    Amended Form 10-Q/A for Fiscal
      Quarter Ended May 31, 2006

    Filed December 20,
      2006

    Form 10-K for Fiscal Year Ended
      August 31, 2006

    Filed December 14,
      2006

    Form 10-Q for Fiscal Quarter
      Ended November 30, 2006

    Filed January 22,
      2007

    File No. 0-13851

Mr. Owings:

     This letter
constitutes Nitches, Inc.'s response to your correspondence dated January 24,
2006 with respect to the above referenced filings. (File No.
0-13851).

     We have prepared
this letter to facilitate your review. Set forth below are copies of the
comments from your letter, and our detailed responses.

Form 10-Q/A for Fiscal Quarter Ended May
31, 2006

    1.

    We note that in response to our
      comments in our letter dated December 4, 2006, you filed a short-form
      amended Form 10-Q/A for fiscal quarter ended May 31, 2006. Please refile
      the full Form lO-Q for fiscal quarter ended May 31, 2006 in a subsequent
      amendment that includes new 302 and 906
  certifications.

     We are
concurrently submitting a second amendment on Form 10-Q/A for the fiscal quarter
ended May 31, 2006 which includes the full Form 10-Q and new 302 and 906
certifications.

Controls and Procedures, page
2

    2.

    We note your response to comment 3
      in our letter dated December 4, 2006. In this regard, we note your added
      disclosure that a "[c]ontrol system, no matter how well designed and
      operated, can provide only reasonable, not absolute, assurance that the
      control system's objectives will be met." Please revise to state clearly,
      if we, that your disclosure controls and procedures are designed to provide reasonable assurance of achieving their objectives and
      that your principal executive officer and principal financial officer
      concluded that your disclosure controls and procedures are effective or
      not effective at that reasonable assurance level. In the alternative,
      please remove the reference to the level of assurance of your disclosure
      controls and procedures. Please refer to Section II.F.4 of Management's
      Reports on Internal Control Over Financial Reporting and Certification of
      Disclosure in Exchange Act Periodic Reports, SEC Release No. 33-8238,
      available on our website at <http://www.sec.gov/rules/final/33-8238.htm>.

     We have revised
our disclosure to state clearly that our controls and procedures are designed to
provide reasonable assurance of achieving their objectives and our chief
executive and financial officers' conclusion of their effectiveness at that
reasonable assurance level.

    3.

    We note your revised disclosure
      that upon re-evaluation, your chief executive and financial officer
      concluded that as of May 31, 2006, the design and operation of your
      disclosure controls and procedures were not effective as of May 31, 2006.
      Please disclose in greater detail the nature of the material weakness
      identified in your disclosure. In this regard, please also revise to
      disclose the specific steps that you are taking or have taken, if any, to
      remediate the material weakness. Further, please disclose when the
      material weakness was identified, by whom it was identified and when the
      material weakness first began.

     We have expanded
our disclosure to describe the deficiency in more detail as well as the specific
steps taken to remediate the weakness.

Exhibits 31.1 and 32.1

    4.

    We note your response to comment 6
      in our letter dated December 4, 2006. It appears, however, that you have
      not used the exact wording of the certification provided in Item
      601(b)(31) of Regulation S-K, as required. For example, paragraph 4(c)
      does not include the parenthetical language. Please revise your 302
      certification to use the exact wording of the certification provided in
      Item 601(b)(31) of Regulation S-K.

     We have revised
our 302 certification to use the exact wording of the certification provided in
Item 601(b)(31) of Regulation S-K.

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Form 10-K for Fiscal Year Ended August 31.
2006 and Form 10-Q for Fiscal Quarter Ended
November 30. 2006

    5.

    Please comply with comments issued on
      the Form 10-Q/A for fiscal quarter ended May 31, 2006, as
      applicable.

     We are
concurrently submitting an amendment on Form 10-K/A for our fiscal year ended
August 31, 2006 and an amendment on Form 10-Q/A for our fiscal quarter ended
November 30, 2006 which contain revisions corresponding to the comments issued
on the Form 10-Q/A for the period ended May 31, 2006, as applicable.

Form 10-K for Fiscal Year Ended August 31,
2006

Controls and Procedures, page
33

    6.

    We note your disclosure that your
      chief executive and financial officer "[o]riginally concluded that, as of
      the end of such period, our disclosure controls and procedures were not
      effective in recording, processing, summarizing and reporting...and are
      effective in ensuring that information required to be disclosed by us in
      the reports that we me or submit under the Exchange Act is accumulated and
      communicated..." It appears that you disclose your chief executive and
      financial officers' original effectiveness conclusion, but not your chief
      executive and financial officers' final effectiveness conclusion. Further,
      please note that the effectiveness conclusion should not be bifurcated,
      but rather stated as a single conclusion of the effectiveness of your
      disclosure controls and procedures as a whole. Please revise your
      disclosure accordingly.

     We have revised
our disclosure to clarify our chief executive and financial officer's final
conclusion of the effectiveness of our disclosure controls in a single
integrated statement.

     Thank you for
your assistance in this matter. Please call me at (858) 625-2636 or James Mercer
of Duane Morris LLP, counsel to Nitches, at (619) 744-2209 if you have any
questions, or if I can be of any assistance.

    Sincerely,

    /s/ Steven P. Wyandt

        Chief Executive Officer

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