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

January 8, 2008

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

    Re:

    Nitches,
      Inc.

    Amendment No.
      1 to Registration Statement on Form
      S-3

    Filed
      December 6, 2007 (File
      No.  333-142478)

    Amendment No.
      1 to Registration Statement on Form
      S-3

    Filed
      December 6, 2007 (File
      No.  333-141659)

Mr. Owings and Ms. Petrillo:

     Nitches,
Inc. ("we,"
"our,"
"us" or the
"Company"),
has filed through EDGAR, Pre-Effective Amendment No. 2 ("Amendment No. 2") to each
of the above-referenced registration statements (the "Registration Statements"). This letter
sets forth the Company's responses to the comments of the staff (the
"Staff") of
the Securities and Exchange Commission (the "Commission") set forth in its comment
letter dated January 4, 2008 (the "Comment
Letter") with respect to the Registration
Statements.

     We have
reproduced below in bold font each of the Staff's comments set forth in the
Comment Letter. Immediately following each such comment is the Company's
response in regular font. The Company's responses in this letter correspond to
the numbers placed adjacent to the Staff's comments in the Comment Letter.

COMMENT 1. Please revise the
"Incorporation by Reference" section in each registration statement to include
the Form 10-K filed on December 21, 2007 as well as the Forms 8-K filed on
December 26, 2007 and January 2, 2008.

RESPONSE: The "Incorporation by Reference" section in each of the Registration
Statements has been revised as requested. In addition, we included other Form
8-Ks that have since been filed.

*
 *    *    *    *    *

     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,

    /s/ Steven P.
      Wyandt

    Chief Executive
      Officer