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                                                            Trombly Business Law
                                                   1320 Centre Street, Suite 202
                                                                Newton, MA 02459
                                                        Telephone (617) 243-0060
                                                        Facsimile (309) 406-1426

Amy  M.  Trombly,  Esq.

September  30,  2005

Delivered  by  electronic  submission  via  EDGAR

United  States  Securities  and  Exchange  Commission
Division  of  Corporation  Finance
100  F  Street,  N.E.,  Mail  Stop  3561
Washington,  DC  20549

     Attn:   Ms.  Michele  M.  Anderson

     Re:     Jane  Butel  Corporation
             Revised  Preliminary  Information  Statement  on  Schedule  14C
             Filed  September  2,  2005
             File  No.  0-50104

Dear  Ms.  Anderson:

I  am  securities counsel for Jane Butel Corporation (the "Company").  I enclose
for  filing  under the Securities Act of 1933, as amended, the Company's revised
preliminary  information  statement  (the  "Information  Statement").

The  Company's revised preliminary information statement contains revisions that
have been made in response to comments received from the staff of the Securities
and  Exchange Commission (the "Staff") in their letter dated September 23, 2005.

Set  forth  below  are  the  Company's  responses  to the Staff's comments.  The
numbering  of  the  responses  corresponds  to  the numbering of comments in the
letter from the Staff.  Additionally, the Company has added information relating
to  an  increase  in  authorized  shares.

Revised  Preliminary  Information  Statement  on  Schedule  14C
---------------------------------------------------------------

Comment 1.     In addition to presenting the beneficial ownership information as
of  the  record  date, revise to update the beneficial ownership table as of the
most  recent practicable date, as required by Item 403 of Regulation S-B.  Also,
revise  the  information statement to discuss the security ownership of Theodore
Smith  prior  to  the merger with Bootie Beer Company and as of the record date.

Response  1.  The  Company  respectfully  notes  that  the  previous 14C already
disclosed the security ownership of Theodore Smith as of the record date.  Since
the  record  date  occurred  before the merger with Bootie Beer, the Company has
also  previously disclosed the security ownership of Theodore Smith prior to the
merger  with  Bootie  Beer  Company.  Additionally,  the  Company  previously
disclosed,  "On  June 10, 2005, the Company experienced a change of control when
Jane  Butel,  a  New  Mexico  resident,  sold  715,000  shares  of  our Series A
Convertible  Preferred  Stock  to  Geneva  Atlantic  Capital  Corp. for $5,000."
Additionally, the Company clarified that, "Ted Smith, who was a director of Jane
Butel  Corporation  at  the  time of the transaction, is the principal of Geneva
Atlantic  Capital  Corp.  The  Company  has added further clarification to state
that,  prior  to receiving the Series A Preferred Stock, Theodore Smith owned no
stock  in  the  Company.

The  Company  has  added an additional updated beneficial ownership as
requested  by  the  Staff.

Comment  2.     Please explain in greater detail why Section 607.1201 applies to
the  sale  of all of your assets and some of your liabilities to Mrs. Butel.  In
this  regard,  address  the  applicability  of  this  statutory  provision while
considering  that  21st Century Technologies was a holder of warrants, and not a
creditor  of  your  company, prior to the settlement of the dispute between Jane
Butel  Corporation  and  21st  Century  Technologies.

Response 2.     The instrument between 21st Century and the Company was titled a
"Warrant Agreement" but was not structured like a typical warrant.  For example,
21st  Century  did  not  have  to  pay an exercise price to obtain the shares of
common  stock  underlying  the Warrant Agreement.  Additionally, the Company was
originally required to issue the shares of common stock six months following the
execution of the document, although this was subsequently modified by the Letter
Agreement.

The  original  Warrant  Agreement  between  the  Company  and  21st  Century
Technologies,  Inc.,  dated  April  23, 2004 was included as Exhibit 10.1 to the
Company's  Form  10-QSB  filed  May  10,  2004.  The  Warrant  Agreement  was
subsequently  modified  through  a  Letter  Agreement.  The  Letter  Agreement
between  the  Company  and 21st Century Technologies, Inc., is  dated  September
15,  2004  and  included  as  Exhibit  10.5  to  the Company's Form 10-KSB filed
September  27,  2004.

Pursuant  to  the  Letter  Agreement,  the  Company  was prohibited from any new
issuance of shares, warrants or options for a period of one year unless approved
in  writing by 21st Century.  If the Company breached that provision, the Letter
Agreement  stated  that,  "all warrants due 21st Century will be due and payable
immediately  in cash."  The Company breached that provision by issuing preferred
shares  within the one year time frame and did not obtain the written permission
of  21st  Century.   As a result, pursuant to the terms of the Warrant Agreement
as  modified  by  the  Letter  Agreement, 21st Century became entitled to a cash
payment  from  the  Company  and  became  a debtor of the Company.  Although the
method  of  how  to calculate the amount of money payable to 21st Century was in
dispute  because  it  is not clearly laid out in either instrument signed by the
parties, the Company believed it would owe 21st Century, at a minimum, what 21st
Century had paid into the Company.  Additionally, the Company believed that 21st
Century  would be entitled to some premium on the money extended to the Company.
Given  that  the  Warrant  Agreement  and  Letter  Agreement provided for a cash
payment  to  21st  Century, the Company believed section 607.1201 applied to the
Company's  final  resolution  of  its debts, including the debt to 21st Century.

Comment  3.     We  reference  your  response analyzing the need for shareholder
approval  of  the  change in control in connection with Mrs. Butel's sale of her
Series  A  preferred  stock.  Clarify  what  you  mean  by the statement in your
response  letter  that  "[a]s this was a private transaction, it did not require
shareholder  approval."  Confirm,  if  true,  that Florida corporate law did not
require  shareholder  approval  of the sale of shares to Geneva Atlantic Capital
Corp.  and the subsequent issuance of shares of common stock to the shareholders
of  Bootie  Beer  Company.

Response  3.     The Company issued the shares of preferred stock to Jane Butel,
a  natural  person.  Jane  Butel,  a  natural  person, sold the shares to Geneva
Atlantic  Capital  Corp.  As  a  natural  person,  Jane  Butel is not subject to
Florida  Corporate  Law.

The  Company  issued  shares  of common stock in connection with the merger
with  Bootie  Beer.  There  is  no  provision  in  Florida  law  that  requires
shareholders  to  approve a specific issuance of stock whether to Bootie Beer or
another  entity or natural person.  We have reprinted the section of Florida law
which  we  believe  may  answer  the  Staff's  question.

607.0621  ISSUANCE  OF  SHARES.--
(1)  The  powers  granted  in  this  section  to  the  board of directors may be
reserved  to  the  shareholders  by  the  articles  of  incorporation.
(2)  The  board of directors may authorize shares to be issued for consideration
consisting of any tangible or intangible property or benefit to the corporation,
including  cash,  promissory  notes,  services  performed,  promises  to perform
services  evidenced  by  a  written  contract,  or  other  securities  of  the
corporation.
(3)  Before the corporation issues shares, the board of directors must determine
that  the  consideration  received  or to be received for shares to be issued is
adequate.  That determination by the board of directors is conclusive insofar as
the  adequacy of consideration for the issuance of shares relates to whether the
shares  are  validly  issued,  fully  paid, and nonassessable. When it cannot be
determined that outstanding shares are fully paid and nonassessable, there shall
be a conclusive presumption that such shares are fully paid and nonassessable if
the  board  of  directors  makes  a  good  faith  determination that there is no
substantial  evidence  that  the full consideration for such shares has not been
paid.
(4)  When  the  corporation  receives  the  consideration for which the board of
directors  authorized  the  issuance  of  shares, the shares issued therefor are
fully  paid  and  nonassessable.  Consideration  in the form of a promise to pay
money  or  a  promise  to perform services is received by the corporation at the
time  of  the  making of the promise, unless the agreement specifically provides
otherwise.
(5)  The corporation may place in escrow shares issued for a contract for future
services  or  benefits  or  a  promissory  note,  or  make other arrangements to
restrict  the transfer of the shares, and may credit distributions in respect of
the  shares  against their purchase price, until the services are performed, the
note  is  paid, or the benefits received. If the services are not performed, the
shares  escrowed or restricted and the distributions credited may be canceled in
whole  or  part.

If  you  have further questions or comments, please feel free to contact us.  We
are  happy  to  cooperate  in  any  way  we  can.

                              Regards,

                              /s/  Amy M. Trombly

                              Amy  M.  Trombly
                              Counsel  for  Jane  Butel  Corporation

cc:     Jane  Butel  Corporation

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