SecProbe.io

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

January 25, 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.
      - Registration Statement on Form S-3 (File No.
      333-142478)

Mr. Owings and Ms. Petrillo:

Pursuant to Rule 461(a) of the rules
and regulations promulgated under the Securities Act of 1933, as amended (the
"Act"),
Nitches, Inc. (the "Company"), hereby requests that the above-referenced registration
statement be declared effective on Tuesday,
January 29, 2008, at 10:00 a.m. Washington, D.C. time, or as soon thereafter as practicable. The Company hereby confirms that
it is aware of its obligations under the Act and under the Securities Exchange
Act of 1934 as they relate to the proposed offering of the securities specified
in the registration statement. The Company 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 the
  Company from its full responsibility for the adequacy and accuracy of the
  disclosure in the filing; and

  the Company may not assert staff comments and 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.

     The
Company respectfully requests confirmation of effectiveness and requests that
the same be communicated to our legal counsel James A. Mercer, III, via
telephone (619.744.2209) or fax (619.744.2201). Your consideration in this
matter is greatly appreciated.

    Sincerely,

    /s/ Steven P.
      Wyandt

    Chief Executive
      Officer