SEC Company Response from NITCHES INC (NICH) (CIK 0000772263) (NICH) — Dec 6, 2007

NITCHES INC (NICH) (CIK 0000772263)
Date: Dec. 6, 2007 · CIK: 0000772263 · Accession: 0001206774-07-002804

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File numbers found in text: 333-141659

Date

December 6, 2007

Author

/s/

Form

CORRESP

Company

NITCHES INC (NICH) (CIK 0000772263)

Letter

Re:

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

December 6, 2007

VIA EDGAR

Messrs. H. Christopher Owings U. S. Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, D.C. 20549

Nitches, Inc.

Registration Statement on Form S-3

Filed March 29, 2007

File No. 333-141659

Messrs. Owing:

Nitches, Inc. ("we," "our," "us" or the "Company"), has filed through EDGAR, Pre-Effective Amendment No. 1 ("Amendment No. 1") to the above-referenced registration statement (the "Registration Statement").

By telephone, we were advised by the staff of the Securities and Exchange Commission (the "Commission") that its sole comment in respect of the Registration Statement was that the Commission was unable to accelerate effectiveness of the Registration Statement until the accounting issues related to our Form 10-K filed for the period ended August 31, 2006 were resolved. All such accounting issues have been resolved as of November 6, 2007.

Further, given the amount of time that has passed since we initially filed the Registration Statement, Amendment No. 1 includes additional and updated information as appropriate.

* * * * * *

Thank you for your assistance in this matter. Please call me at (858) 731-0520 or James A. Mercer III of Duane Morris LLP, our outside legal counsel, at (619) 744-2209 if you have any questions, or if we can be of any assistance.

Sincerely,
Nitches, Inc.

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CORRESP
1
filename1.htm

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

December 6, 2007

VIA EDGAR

Messrs. H. Christopher
Owings
U. S. Securities and Exchange
Commission
Division of Corporation Finance
100 F. Street,
N.E.
Washington, D.C. 20549

    Re:

    Nitches, Inc.

    Registration Statement on Form S-3

    Filed March 29, 2007

    File No. 333-141659

Messrs. Owing:

     Nitches,
Inc. ("we," "our," "us" or the "Company"), has filed through EDGAR,
Pre-Effective Amendment No. 1 ("Amendment No. 1") to the above-referenced
registration statement (the "Registration Statement").

     By
telephone, we were advised by the staff of the Securities and Exchange
Commission (the "Commission") that its sole comment in respect of the
Registration Statement was that the Commission was unable to accelerate
effectiveness of the Registration Statement until the accounting issues related
to our Form 10-K filed for the period ended August 31, 2006 were resolved. All
such accounting issues have been resolved as of November 6, 2007.

     Further,
given the amount of time that has passed since we initially filed the
Registration Statement, Amendment No. 1 includes additional and updated
information as appropriate.

*     *
   *     *     *     *

     Thank you
for your assistance in this matter. Please call me at (858) 731-0520 or James A.
Mercer III of Duane Morris LLP, our outside legal counsel, at (619) 744-2209 if
you have any questions, or if we can be of any assistance.

    Sincerely,

    Nitches, Inc.

    /s/
    Steven P. Wyandt

    Chief
      Executive Officer

SecProbe.io