SecProbe.io

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Mail Stop 3561

                              December 29, 2005

Mr. Leonard H. Luner
Chief Executive Officer and Chief Financial Officer
Originally New York, Inc.
2505 Anthem Village Drive
Suite E-404
Henderson, NV 89052

      Re:	Originally New York, Inc.
      Form 10-KSB for the Fiscal Year Ended December 31, 2004
      Filed April 8, 2005
      Form 10-QSB for the Quarter Ended September 30, 2005
      Filed November 14, 2005
      File No. 0-50013

Dear Mr. Luner:

      We have reviewed your filings 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
information so we may better understand your disclosure.  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 comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

1. Unless otherwise indicated, where a comment below requests
additional disclosures or other revisions to be made, these
revisions
should be included in your future filings, as applicable.
2. Please amend your filing to include all the information
required
by Item 9(e) of Schedule 14A in "Item 14.  Principal Accountant
Fees
and Services" which was added by Release No. 33-8183.  The new
disclosure requirements were effective for annual reports for the
first fiscal year ending after December 15, 2003.

Financial Statements, page F-1

Notes to Financial Statements, page F-6

Note 9 - Related Party Transactions, page F-10

3. We note your transfer of assets to your President in exchange
for
the reduction of accrued executive compensation in the amount of
$6,307.  Given that you have no assets other than cash, please
tell
us how you plan on operating your business and whether you intend
on
liquidating the business.  Tell us specifically whether the
Company
is renting fixed assets and website development from the President
or
whether their use is being donated by the President.
Additionally,
since the Company possesses no inventory, tell us how sales will
be
generated and how an order will be fulfilled if a customer
purchases
a product from your website.

Item 14.  Controls and Procedures, page 33

4. Please amend your filing to indicate whether your disclosure
controls and procedures are effective as of the end of the period
covered by this report (not within 90 days of the filing date.)
Also
disclose any change in your internal control over financial
reporting
that occurred during your last fiscal quarter (fourth fiscal
quarter
in the case of an annual report) that has materially affected, or
is
reasonably likely to materially affect your internal control over
financial reporting.  Refer to Items 307 and 308(c) of Regulation
S-B
and SEC Release No. 33-8238.  Furthermore, please re-number this
as
Item 8A in your Form 10-KSB.  Refer to the Form 10-KSB Official
Text.

Certification

5. Please amend your filing to correct your certifications.  The
wording should be exactly as specified in Item 601 of Regulation
S-B.
Refer to SEC Release 33-8238.

Form 10-QSB for the Quarterly Period Ended September 30, 2005

6. We note in your Form 8-K filed on August 3, 2005 that Beckstead
and Watts, LLP resigned as your independent registered public
accounting firm and that you intend to file a Form 8-K when you
retain new independent accountants.  To date, you have not filed a
Form 8-K disclosing your new independent accountants.  Please tell
us
whether you have retained new independent accountants and whether
they have reviewed your interim financial statements included in
quarterly reports filed on Form 10-QSB.  Please be advised that
while
interim financial statements may be unaudited, they must be
reviewed
prior to filing, by an independent public accounting using
professional standards and procedures for conducting such reviews.
Please refer to Item 310(b) of Regulation S-B.

Financial Statements, page 4

Statements of Cash Flows, page 6

7. In future filings, please present your statements of cash flows
for the interim period up to the date that a balance sheet is
presented.  For example, in this quarterly report, a statement of
cash flows should be presented for the nine months ended September
30, 2005 and 2004, not for the three months ended September 30,
2005
and 2004.  Refer to Item 310(b) of Regulation S-B.

Item 3.  Controls and Procedures, page 9

8. In future filings, please revise to indicate whether your
disclosure controls and procedures are effective as of the end of
the
period covered by the report (not within 90 days of the filing
date.)
In addition, you should disclose any change in your internal
control
over financial reporting that occurred during the fiscal quarter
covered by the quarterly report, that has materially affected, or
is
reasonably likely to materially affect, the company`s internal
control over financial reporting.  Refer to Items 307 and 308(c)
of
Regulation S-B and SEC Release No. 33-8238.

Certification

9. In future filings, please correct your certification.  The
wording
should be exactly as specified in Item 601 of Regulation S-B.
Refer
to SEC Release 33-8238.

*      *      *      *      *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed response letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and 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.

		You may contact Yong Kim at (202) 551-3323 if you have
any
questions regarding these comments.  Please contact me at (202)
551-
3716 with any other questions.

							Sincerely,

							William Choi
							Branch Chief
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Mr. Leonard H. Luner
Originally New York, Inc.
December 29, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

         DIVISION OF
CORPORATION FINANCE

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