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

January 24, 2008

VIA EDGAR
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. 3 to
      Registration Statement on Form S-3 (File
      No.  333-142478)

    Amendment No. 3 to
      Registration Statement on Form S-3 (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. 3 to each of the
above-referenced registration statements (the "Registration Statements"). The Company
filed a Pre-Effective Amendment No. 2 to each of the Registration Statements on
January 9, 2008. We were advised that the Commission had no further comment to
the Registration Statements. However, because the Company did not timely file
its Quarterly Report on Form 10-Q for the period ended November 30, 2007, we
were advised that we would have to file a Pre-Effective Amendment No. 3 to each
of the Registration Statements to update the "Incorporation by Reference"
section in each of the Registration Statements to include the Quarterly Report
on Form 10-Q for the period ended November 30, 2007. That quarterly report was
filed on January 24, 2008. Accordingly, among other items that were updated, the
"Incorporation by Reference" section in each of the Registration Statements was
revised to include the Quarterly Report on Form 10-Q for the period ended
November 30, 2007.

     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