SecProbe.io

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Mail Stop 0308

October 20, 2004

VIA U.S. MAIL AND FACSIMILE

Mr. Dwight Webb
President and Chief Executive Officer
Vita Equity, Inc.
Suite 314 - 837 West Hastings Street
Vancouver, British Columbia V6C 3N6
Canada

Re:	Vita Equity, Inc.
Form SB-2 filed on September 21, 2004
File No.:  333-119147

Dear Mr. Webb:

      We have reviewed the document listed above and have the
following comments.  Where indicated, we think you should revise
your
document in response to these comments.  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.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
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 comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Facing Page, page i

1. Please check the first box on the cover page to indicate that
selling shareholders will offer the securities on a delayed or
continuous basis.

Cover Page, page ii

2. This registration statement is registering 100% of your
currently
outstanding common stock, 36.7% of which is being offered by
affiliates of the company directly.  Generally, we view resale
transactions by parties related to the issuer of this amount as,
in
essence, an offering by or on behalf of the issuer for purposes of
Rule 415(a)(4) of Regulation C under the Securities Act.  For
these
sales to occur "at the market," the provisions of Rule 415(a)(4)
must
be satisfied.  As your offering does not appear to meet these
provisions, an "at the market" offering by those affiliates is not
permissible.  Your offering should be revised to price the shares
being offered by affiliates for the duration of the offering.  The
affiliates must resell their securities for the $0.05 per share
price
for the duration of the offering. The prospectus should also make
clear the fact that these persons are considered underwriters of
this
offering.  Revise your prospectus accordingly, including your
cover
page, summary, and plan of distribution section.

3. Please disclose that the selling stockholders will receive all
of
the proceeds from the sale of the common stock.

Inside Front and Outside Back Cover Pages of Prospectus, page iii

4. Please indicate where your Dealer Prospectus Delivery
Obligation
statement is located.  If you believe that this statement is not
required, please tell us why you have not included it.  See Item
502(b) of Regulation S-B.

5. Please revise your Table of Contents to ensure that the
headings
and subheadings correspond to the correct page numbers.

Prospectus Summary, page 1

6. You refer to financial projections delivered herewith.  Please
tell us whether you anticipate delivering any projections that are
not included in the registration statement.  If not, revise the
paragraph to make clear that the projections are included in the
registration statement.

The Company, page 1

7. In this section, please include an expanded discussion of your
business.  In the "Description of Business" section, please
describe
in greater detail the material aspects of your business,
including,
but not limited to, the following:

* the total sales figures in dollars since the opening of your
business and the dollar amount of jewelry you have sold thus far;
* the space, quantity, and size of your storefront or other
establishment through which you conduct your business operations;
* the countries from which you acquire your non-domestic precious
metal and stones and the inherent risks, if any, in not being able
to
acquire your necessary materials for your customers;
* the fact that you are a custom jewelry designer and manufacturer
and whether your jewelry is designed for high-end, middle range,
or
other customers.

The Offering, page 1

8. In this section, you stated that you are to register 13,320,000
shares of your common stock.  However, in the other sections of
your
Prospectus, you state that the number of shares is to be
13,220,000.
Please provide the correct number of shares and be sure that the
number is consistent throughout the document.

Risk Factors, page 3

9. In the first paragraph, please revise to make clear that you
have
identified all material risks known to and anticipated by you at
present.  In case you have not included all such risks in this
section, please do so.

10. Include a risk factor discussing the application of the penny
stock rules to trading in your securities.  We note that you have
provided similar disclosure in the Plan of Distribution

11. In this section, please alert your investors to the fact that
your business condition raises substantial doubt as to your
continuing to operate as a going concern.

12. In your second paragraph, you state that you have only one
officer and director.  However, in your third paragraph you refer
to
"officers" and "directors."  Also, in your section entitled
"Directors, Executive Officers, Promoters and Control Persons,"
you
list two directors and two officers.  Please revise or explain
this
discrepancy.

We may not achieve sufficient brand recognition, page 4

13. Quantify the amount of expenditures you anticipate making on
your
"aggressive brand-enhancement strategy."  Provide full disclosure
regarding anticipated marketing expenses in the business section.

Because we depend on third party suppliers and contract
craftspeople
. . ., page 4

14. Please describe in a meaningful way the "limited number of
third-
party suppliers."  Your discussion should include the number of
suppliers upon which you rely, whether there are any alternative
suppliers, the importance of each material in the manufacturing of
your products, and the percentage of each material you purchase
from
each supplier.

Because we currently sell all of our manufactured product to two
clients . . . , page 5

15. Please disclose the name and relation of the related party who
is
one of your customers.

Risks Related to the Industry, page 5

16. Please state whether you face any political risks from foreign
governments besides regulation and legislation risks, such as
instability or political turmoil.

Dividend Policy, page 7

17. Please describe your plans for, and the likelihood of, future
dividend payments to your shareholders.  Please discuss your plans
in
the context of your financial situation.

Selling Stockholders, page 7

18. Please identify the natural person(s) or public company that
has
the ultimate voting or investment control over Nuvo Magazine,
Ltd.`s
shares listed in the Selling Shareholder Table.

19. Please list or reference the periods of time that Dwight Webb
has
been President and Director, and the periods of time that George
Polyhronopoulos was Director and Officer.  See Item 507 of
Regulation
S-B.

20. Please explain why your offering lasting between September 15,
2000 and January 31, 2001 for 12,300,000 shares was cancelled and
the
subscription money refunded on March 1, 2003.

21. In the second sentence of your third paragraph, you state that
Mr. Polyhronopoulos acted as your "first Director and officers."
Please clarify and list his executive positions.

22. We note that you have made sales to related parties.  Please
tell
us why you have not identified those sales in your discussion of
material relationships between you and the shareholders.

Plan of Distribution, page 9

23. Please state that if you add a broker-dealer or underwriter,
you
will file a post-effective amendment to this Prospectus.

24. Tell us why the company is paying all fees and expenses
incident
to the registration of shares.  If there are agreements describing
registration rights associated with outstanding securities, you
should file those documents as material agreements.

Legal Proceedings, page 10

25. Clearly state that there are no pending material legal
proceedings without including a knowledge qualifier.

Directors, Executive Officers, Promoters and Control Persons, page
10

26. You state that Mr. Webb was appointed to the Board of
Directors
in August 2000 for a one-year term and that Mr. Hu was appointed
to
the Board in January 2001 to serve a one-year term as well.
Please
clarify if these appointments had been renewed every year since
that
time.  If their appointments have not been continuous, please
state.
See Item 401(a) of Regulation S-B.

27. Please indicate when Mr. Webb was appointed President and
Chief
Executive Officer and if he has had any other positions with your
company.  See Item 401(a) of Regulation S-B.

28. You described Mr. Hu`s business experience over the last five
years as being "a self-employed businessperson in the food and
beverage industry."  Please provide greater detail about this
business and his experience during this employment.  See Item
401(a)(4) of Regulation S-B.

29. If any, please describe the family relationships that exist
among
executive officers, directors, and nominated persons to those
positions in accordance with Item 401(c).  See Items 401(c) of
Regulation S-B.

Security Ownership of Directors, Officers, and Management, page 11

30. In the table, please add a line item for the shares
beneficially
owned by your directors and executive officers as a group, without
naming them individually.  See Item 403(b) of Regulation S-B.

31. In a footnote to your table, please state the amount of
shares,
if any, shown in Column (3) that the listed beneficial owner has
the
right to acquire within 60 days from rights, conversion
privileges,
or similar obligations.  Also, please be sure to calculate the
percentages in that column on the basis of the amount of
outstanding
securities plus, for each person or group, any securities that a
person or group has the right to acquire within 60 days pursuant
to
options, warrants, conversion privileges, or other rights.  See
Instructions 1 and 3 to Item 403 of Regulation S-B.
Description of Securities, page 11

32. Please remove the qualification in your "Description of
Securities" section that states the description of your authorized
capital stock "is subject to" your Articles of Incorporation.  If
any
information in this section is inconsistent with your Articles of
Incorporation, please remove that information from this
Registration
Statement.

33. Please describe any preemption rights.  See Item 202(a)(1) of
Regulation S-B.

34. In this section, you state that you have four directors.
However, in the section entitled "Directors, Executive Officers,
Promoters and Control Persons," you list only two directors,
Dwight
Webb and Michael Hu.  Please either revise your statement in this
section to reflect the correct number of directors, or amend the
rest
of your registration statement to include the correct amount of
and
information on your other directors.

Redemption, page 12

35. Please describe the redemption rights by describing the
provisions of the Nevada Revised Statutes, Chapter 78.  Similarly,
explain what a payment of a distribution in violation of Section
78.300 would be, as referenced on page 13.

Liquidation Rights, page 12

36. Please clearly describe the liquidation rights.  It appears
that
the first sentence is incomplete.

Certain Provisions of the Articles of Incorporation, page 12

37. Please only describe any provision in the charter or by-laws
that
would delay, defer, or prevent a change in control of your
company.

Experts, page 12

38. The Experts section states that the financial statements are
incorporated by reference.  This is not correct.  Please revise to
correct this statement.

39. The document includes both audited and unaudited financial
statements.  Please revise the Experts section to indicate that
Weinberg has only audited the annual financial statements.

History and Background, page 13

40. Please state whether Dwight Webb is a full-time or part-time
employee.  Also, you state that Dwight Webb is your only employee,
however Mauro Baessato is listed as Secretary and Treasurer.
Please
explain his duties and why he is not considered an employee.

Products and Services, page 14

41. Please explain your business strategy.  Also, please provide
support for your belief that your business strategy is expected to
enable you to become "well-recognized and reputable for [your]
creative and unique designs in the custom jewelry industry."

42. Please elaborate on how you can "leverage your expertise and
existing customers to potentially increase sales in the much
larger
markets of Canada and the United States."

Jewelry, page 14

43. Please clarify whether you have inventory currently.  It
appears
from your Financial Statements that you have none.  If you do have
inventory, please quantify the amount and describe the kind of raw
materials that you keep in your inventory and the amount of raw
materials that you have to acquire.  If you have no inventory,
please
state and revise any assertions that you have inventory.

44. Please name and describe your principal wholesalers of raw
materials and what you mean by "with whom we have relationships."
Furthermore, please discuss the availability of the raw materials
you
need from these wholesalers.  See Item 101(b)(5) of Regulation S-
B.

45. Please describe your arrangements with your third party
jewelry-
makers.  You should discuss their compensation, availability,
means
of selection, and any other matters you believe are material.

46. Please discuss your dependence on your few major clients.  In
your "Summary Information and Risk Factors" section, you stated
that
you had only two customers at the present time.  Please identify
these material customers.  See Item 101(b)(6) of Regulation S-B.

47. Please state whether you have any patents, trademarks,
licenses,
franchises, concessions, royalty agreements, or labor contracts,
including their duration.  If you have none, please state.  See
Item
101(b)(7) of Regulation S-B.

Marketing and Promotion Strategy, page 14

48. Please provide the expected costs of your marketing efforts.
Furthermore, please state whether you believe these plans are
feasible for your company in the near future.

49. Please estimate the amount you spent during each of the last
two
fiscal years on research and development activities, and, if
applicable, the extent to which the cost of such activities is
borne
directly by your customers as "mark-up."  See Item 101(b)(10) of
Regulation S-B.

Competition, page 15

50. Please provide the facts and reasons underlying your assertion
that "the individual treatment and interaction with our customers
provides us with a competitive edge over mass manufacturers in
certain markets."

51. You state that you are in a "highly competitive industry."
Please identify your main local competitors and your competitive
position in your industry and market.  See Item 101(b)(4) of
Regulation S-B.

Regulatory Background, page 15

52. In this section, you discuss foreign government mining,
production, and marketing regulations of the diamond industry.  In
addition, please discuss the effect of regulations with which you
anticipate having to comply in the United States and Canada, if
any,
that correspond to or surpass mining, production, and marketing.
Please focus on specific regulations that currently affect you or
are
likely to affect you in the near future.  See Item 101(b)(9) of
Regulation S-B.

Disclosure, page 15

53. Revise this disclosure so it complies with the requirements of
101(c)(3) of Regulation S-B.  You should refer to proxy and
informa