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CORRESP
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      TIML CORRESP 11-28-2005

                TIME
                  LENDING, CALIFORNIA, INC.

                1040
                  E. Katella Ave., Suite B1

                Orange,
                  California 92867

                (714)
                  288-5901

                    November
      28,
      2005

    Larry
      Spirgel

    Assistant
      Director

    Securities
      and Exchange Commission

    450
      Fifth
      Street, N.W.

    Washington,
      DC 20549

                    Re:

                TIME
                  LENDING, CALIFORNIA, INC. (THE "COMPANY")

                FORM
                  10-KSB FOR THE FISCAL YEAR ENDED JUNE 30, 2005

                FILED
                  SEPTEMBER 28, 2005

                FILE
                  NO. 333-59114

    Dear
      Mr.
      Spirgel:

        The
      Company
      responds to the Staff's comment letter dated November 1,

    2005.
      The
      Staff's comments are addressed by their corresponding numbers and
      are

    accompanied
      by the Company's responses thereto.

    Form
      10-KSBfor the year ended June 30, 2005

    Accounting
      Comments

    Report
      of Independent Public Accounting Firm, Page 14

            1.

              The
                audit report of Michael B. Johnson & Co, LLC has been included in the
                amended Form 10-KSB for the fiscal year ended June 30,
                2005.

    Consolidated
      Statement of Stockholders’ Equity (Deficit), page 18

            2.

              The
                stock issuance to the employees for compensation were set at $.01
                per
                share by management as estimated fair value for the services. This
                is the
                estimated fair value, as during the year a four- for- one (4- for-1)
                forward split was approved by the Board of Directors . Both Michael
                Pope
                and Philip La Puma received 5,002,000 shares of common stock in the
                Company. This represented $50,020 each of their annual compensation.
                This
                value was set on restricted shares of common during a period of no
                public
                trading.

            3.

              Please
                see changes to Note 1 (“Net earnings per share “ and “Stock Based
                Compensation” have been added) to the amended Form 10-KSB for the fiscal
                year ended June 30, 2005.

    NET
      EARNING (LOSS) PER SHARE

    Basic
      loss per share is computed on the basis of the weighted average number of

    common
      shares outstanding. For all periods, all of the Company’s common stock

    equivalents
      were excluded from the calculation of diluted losses per common share

    because
      they were none dilutive, due to the Company’s net losses.

    STOCK
      BASED COMPENSATION

    The
      Company has adopted for footnote disclosure purposes SFAS No. 123, which
      requires that

    Companies
      disclose the cost of stock-based employee compensation at the grant date based

    on
      the value of the award (the fair value method) and disclose this cost over
      the
      service period.

    The
      value of the stock-based award is determined using a pricing model whereby
      compensation

    cost
      is the excess of the fair value of the award as determined by the model at
      grant
      date

    or
      other measurement date over the amount an employee must pay to acquire the
      stock.

Awards through June 30, 2005 have been at fair value.

    Notes
      to Consolidated Financial Statements

    Note
      1. Organization and Presentation

    Net
      Earning (Loss) per share, page 20

            4.

              None
                of the shares were determined to be
                dilutive.

    Note
      6. Capital Stock Transactions

    The
      Company effected a four- for- one (4- for- 1) forward split of its issued and
      outstanding common stock as of May 2005.

    The
      Company is responsible for the adequacy and accuracy of the disclosure in the
      filings; staff comments or changes to disclosure in response to staff comments
      in the filings reviewed by staff 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.

    Very
      truly yours,

    Michael
      Pope, President