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CORRESP
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filename1.htm

Response to Letter from SEC

100-1001
Churchill Crescent

North
Vancouver, British Columbia

Canada
V7P 1P9

Tel:
604-980-6693 Fax: 604-980-6675

[VITASTI Graphic
Reference]

December
22, 2005

VIA
EDGAR ONLY

Robert
Telewicz

Staff
Accountant

Securities
and Exchange Commission

Division
of Corporation Finance

450 Fifth
Street, N.W.

Washington
DC 20549

RE:     Vitasti,
Inc. File No. 000-26371

Form
8-K filed November 18, 2005

Item
4.02

Dear Mr.
Telewicz:

On behalf
of Vitasti, Inc. (“Vitasti” or the “Company”), please be advised that I am in
receipt of your letter dated November 28, 2005 with respect to the
above-referenced matter.

Please
accept this letter in lieu of a more formal response to each comment set forth
in your letter.

The
restated financials should be filed no later than January 15, 2005. The
Company’s auditor is in the process of organizing the information and expects to
complete in short order.

As it
pertains to the Company’s Disclosure Controls and Procedures for the year ended
December 31, 2004, and each subsequent quarter to date, i.e. March 31, 2005,
June 30, 2005 and September 30, 2005, please be advised that the Registrant's
Board of Directors and Chief Financial Officer have reevaluated the Registrant's
disclosure controls and procedures (as defined in Rule 13a-15(e) promulgated
under the Securities and Exchange Act of 1934, as amended ("'34 Act")) and
believes that they are effective to provide reasonable assurance that
information required to be disclosed by the Registrant in reports filed or
submitted by it under the '34 Act are recorded, processed, summarized and
reported within the time periods specified in the '34 Act rules and form, and to
provide reasonable assurance that information required to be disclosed by the
Company is accumulated and communicated to the Company's management, including
the Company's Chief Executive Officer and Chief Financial Officer, as
appropriate to allow timely decisions regarding disclosure. The Registrant
believes that the Low Carb Companies-Global Golf Holdings, Inc. transaction is
not one that the Registrant encounters in its normal course of business and
should not be a recurring event. However, the Registrant is evaluating ways to
ensure that its financial statements are always presented in a clear, concise
and accurate manner. To achieve that result, and for the year ended December 31,
2005, as applicable, the Registrant is considering: (1) expanding its internal
accounting staff; (2) when confronted with an accounting presentation of a
complex transaction in the future, seeking the opinion of additional financial
reporting advisory firms; and, (3) to the extent permissible and permitted by
regulation and law, seeking guidance from the Division of Corporate Finance of
the Securities and Exchange Commission, regarding the applicable accounting
principles and presentation in question.

On behalf
of the Company, please be further advised that the Company hereby acknowledges
the following:

    (1)

      the
      Company is responsible for the accuracy and adequacy of the disclosures in
      the filings;

    (2)

      Staff
      comments or changes to disclosures in response to Staff comments do not
      foreclose the commission from taking any action with respect to the
      filings; and

    (3)

      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.

Thank you
for your attention to this matter. To the extent that you have additional
comments or concerns, please contact me directly or the Company's attorneys, the
Steady Law Group, LLP, at (619) 892-3006.

Very
truly yours,

/s/ TAMMY-LYNN MCNABB

Tammy-Lynn
McNabb,

President
& CEO

cc: Steady
Law Group, LLP