SecProbe.io

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Mail Stop 4561
      November 9, 2005

Ms. Tammy-Lynn McNabb
Chief Executive Officer
Vitasti, Inc.
100-1001 Churchill Crescent
North Vancouver, B.C., Canada, V7P 1T2

	RE:	Vitasti, Inc.
		Forms 8-K and 8-K/A
		Filed November 9, 2005 and November 9, 2005
            	File No. 0-26673

Dear Ms. McNabb:

      We have reviewed your filing and have the following comment.
Where indicated, we think you should revise your document in
response
to this comment.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  After
reviewing this information, we may raise additional comments.

      	Please understand that the purpose of our review process
is
to assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call me at the telephone number
listed
at the end of this letter.

Form 8-K filed November 8, 2005

1. Please amend your form 8-K to comply with all of the
requirements
of Regulation S-K Item 304 (a)(2).  In making any disclosures
about
consultations with your new accountants, please ensure you
disclose
any consultations up through the date of engagement.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed investment decision.  Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	Please provide the information requested above within five
business days from the date of this letter.  The information
should
be filed as correspondence on EDGAR.

      Any questions regarding the above should be directed to me
at
(202) 551-3432.

								Sincerely,

								William Demarest
								Staff Accountant
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Ms. Tammy-Lynn McNabb
Vitasti, Inc.
November 9, 2005
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