SecProbe.io

CORRESP
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      LEVY&
        BOONSHOFT,
        P.C.

      ATTORNEYS
        AT LAW

      477
        Madison
        Avenue

      New
        York,
        New York 10022

      (212)
        751-1414

      Facsimile:
        (212) 751-6943

      December
        7, 2005

      VIA
        EDGAR AND FEDERAL EXPRESS

      Securities
        and Exchange Commission

      450
        Fifth
        Street, N.W.

      Washington,
        D.C. 20549

      Attention:
        Owen Pinkerton, Esq.

                  Re:

                    TNT
                      Designs, Inc.

                    Registration
                      Statement Form SB-2, filed April 8, 2005

                    File
                      No. 333-123941

      Dear
        Mr.
        Pinkerton:

      Please
        be
        advised that this firm has recently been retained as special securities counsel
        to TNT Designs, Inc. (“TNT”). Reference is made to the Commission’s comment
        letter dated October 28, 2005 relative to TNT’s Amendment No. 1 to its
        Registration Statement Form SB-2. In response to these comments, TNT has
        caused
        to be filed Amendment No. 2 to the Form SB-2, a redlined copy of which is
        enclosed with the original correspondence to show revisions to the filing.
        The
        purpose of this correspondence is to illustrate those changes to the Commission
        and provide explanation, where necessary. The items herein bear the same
        numbering as the Commission’s comment letter.

      General

                1.

                Please
                  note that amendments in a registration statement must be numbered
                  consecutively in the order in which they are filed. In this regard,
                  we
                  note that you this amendment is not properly numbered as amendment
                  no. 1.
                  Se Rule 470 of Regulation C.

                The
                  most recently filed amendment to the Form SB-2 has been properly
                  numbered
                  as “Amendment No. 2.”

      Cover
        Page

                2.

                Please
                  advise us as to why you have included the paragraph below the
                  cross-references to the “Risk Factors” section in which you state that the
                  prospectus may be supplemented or amended and that investors should
                  read
                  any such amendment or supplement before investing. Since this offering
                  will be a continuous offering and preliminary prospectuses will
                  presumably
                  not be circulated, please advise us as to why this paragraph is
                  necessary.
                  We note, for example, that only the final prospectus will be circulated
                  to
                  and any supplements filed would be stickered to the final prospectus.
                  Please revise or advise. This comment also refers to similar language
                  found on page 16.

                The
                  language regarding amendments to the prospectus has been
                  deleted.

      Securities
        and Exchange Commission

        December
          7, 2005

        Page
          2

        LEVY
          & BOONSHOFT, P.C.

      Risk
        Factors, page 4

                3.

                Please
                  avoid using generic conclusions such as “adversely affected” when
                  describing the risks’ effects. For example, without limitation, we note
                  that on page 9 you state that your “business” may be adversely affected by
                  a unilateral termination of your agreement with Radico or your
                  inability
                  to meet minimum requirements. Explain the specific effect this
                  risk will
                  have on your business. Replace this, and similar language, with
                  specific
                  disclosure of how you, your business, financial condition and results
                  of
                  operations would be affected by the facts you
                  describe.

                The
                  references to TNT’s business being “adversely affected” has been revised
                  to state the following:

                TNT
                  CURRENTLY IS A PARTY TO ONLY ONE ALLIANCE AGREEMENT AS THE SOURCE
                  FOR
                  PRODUCTS WE INTEND TO SELL AND SHOULD THERE BE A BREACH UNDER THE
                  AGREEMENT BY EITHER PARTY OR A PROBLEM OBTAINING PRODUCT UNDER
                  THE
                  AGREEMENT WE MAY BE UNABLE TO CONSUMMATE SALES AND GENERATE REVENUE
                  AND
                  PROFITS.

                Our
                  sole alliance agreement for the importation and sale of our products
                  is
                  with Radico Import Export Ltd., an Indian corporation. Should we
                  have
                  difficulty obtaining apparel products from Radico or should we
                  have
                  difficulty entering into other alliance agreements for importing
                  products
                  from other sources, our business operations may be unable to consummate
                  any sales and we may required to cease operations.

                TNT
                  IS DEPENDENT ON ENTERING INTO STRATEGIC ALLIANCES AND DISTRIBUTORSHIP
                  AGREEMENTS WITH THIRD PARTIES FOR PRODUCTS THAT TNT INTENDS TO
                  SELL.

                As
                  a wholesaler and distributor of women’s accessories and cosmetics, TNT
                  does not produce nor does it intend to produce any products that
                  TNT
                  intends to sell, but rather TNT intends to obtain these products
                  from
                  third parties under alliances or distribution agreements TNT may
                  enter
                  into. TNT is currently a party to a single agreement. In the event
                  TNT’s
                  current alliance agreement is not successful or TNT can not enter
                  into
                  additional alliance or distribution agreements with parties for
                  products
                  that are acceptable to consumers, may be unable to effectuate sales
                  or
                  conduct revenue generating operations.

                TNT
                  HAS YET TO ATTAIN PROFITABLE OPERATIONS AND BECAUSE TNT WILL NEED
                  ADDITIONAL FINANCING TO FUND THE DEVELOPMENT OF BUSINESS, TNT MAY
                  EXPERIENCE DIFFICULTY IN ITS EFFORTS TO CONTINUE AS A GOING CONCERN.

                TNT
                  has incurred a net loss of $27,772 for the period from February
                  17, 2004
                  (inception) to September 30, 2005, and has no revenues to date.
                  The
                  successful implementation of our business plan is dependent upon
                  future
                  profitable operations from the development of our business. Our
                  financial
                  statements included with this prospectus have been prepared assuming
                  that
                  TNT will continue as a going concern. A going concern paragraph
                  has not
                  been issued in that TNT currently has adequate cash on hand to
                  fund our
                  current monthly operating expenses for a period of five (5) months.
                  However TNT may fail to remain a going concern should we seek to
                  expand
                  business operations and effectuate the TNT business plan as anticipated
                  (See “Plan of Operation” herein) without additional financing. If TNT is
                  not able to achieve revenues or obtain financing, then TNT may
                  not be able
                  to commence revenue generating operations or to continue as a going
                  concern.

          Securities
            and Exchange Commission

            December
              7, 2005

            Page
              3

            LEVY
              & BOONSHOFT, P.C.

                  THERE
                    IS NO ACTIVE TRADING MARKET FOR OUR COMMON STOCK AND IF A MARKET
                    FOR OUR
                    COMMON STOCK DOES NOT DEVELOP, OUR INVESTORS MAY HAVE DIFFICULTY
                    IN
                    ATTEMPTING TO SELL THEIR SHARES.

                There
                  is currently no active trading market for our common stock and
                  such a
                  market may not develop or be sustained. TNT currently plans to
                  have its
                  common stock quoted on the National Association of Securities Dealers
                  Inc.’s OTC Bulletin Board upon the effectiveness of this registration
                  statement of which this prospectus forms a part. In order to do
                  this, a
                  market maker must file a Form 15c-211 to allow the market maker
                  to make a
                  market in our shares of common stock. At the date hereof, Ms. Tandon,
                  the
                  sole officer and director of TNT is not aware that any market maker
                  has
                  any such intention. TNT Designs cannot provide investors with any
                  assurance that TNT’s common stock will be traded on the OTC Bulletin Board
                  or, if traded, that a public market will materialize. Further,
                  the OTC
                  Bulletin Board is not a listing service or exchange, but is instead
                  a
                  dealer quotation service for subscribing members. If TNT’s common stock is
                  not quoted on the OTC Bulletin Board or if a public market for
                  TNT’s
                  common stock does not develop, then investors may have difficulty
                  selling
                  the shares of our common stock. If TNT establishes a trading market
                  for
                  its common stock, the market price of the common stock may fluctuate
                  significantly and be significantly affected by factors such as
                  actual or
                  anticipated fluctuations in operation results, general market conditions
                  and other factors. In addition, the stock market has from time
                  to time
                  experienced significant price and volume fluctuations that have
                  particularly affected the market prices for the shares of developmental
                  stage companies, which may materially cause the market price of
                  TNT’s
                  common stock to decline.

                SALES
                  OF A SUBSTANTIAL NUMBER OF SHARES OF OUR COMMON STOCK INTO THE
                  PUBLIC
                  MARKET
                  BY SELLING STOCKHOLDERS MAY RESULT IN SIGNIFICANT DOWNWARD PRESSURE
                  ON THE
                  PRICE OF OUR COMMON STOCK AND COULD AFFECT THE ABILITY OF OUR STOCKHOLDERS
                  TO REALIZE ANY CURRENT TRADING PRICE OF OUR COMMON STOCK.

                Sales
                  of a substantial number of shares of our common stock in the public
                  market
                  could cause a reduction in the market price of our common stock,
                  when and
                  if such a market develops. When this registration statement is
                  declared
                  effective, the selling stockholders may be reselling up to 34.6%
                  of the
                  issued and outstanding shares of our common stock. As a result
                  of such
                  registration statement, a substantial number of our shares of common
                  stock
                  which have been issued may be available for immediate resale when
                  and if a
                  market develops for our common stock, which could cause the price
                  of our
                  common stock to decline. As a result of any such decreases in price
                  of our
                  common stock, purchasers who acquire shares from the selling stockholders
                  may lose some or all of their investment.

                NASD
                  SALES PRACTICE REQUIREMENTS MAY ALSO LIMIT A STOCKHOLDER’S ABILITY TO BUY
                  AND SELL OUR STOCK.

        Securities
          and Exchange Commission

          December
            7, 2005

          Page
            4

          LEVY
&
            BOONSHOFT,
            P.C.

                In
                  addition to the “penny stock” rules promulgated by the Securities and
                  Exchange Commission (see above and the “Market for Common Equity and
                  Related Stockholder Matters” section at page 14 for discussions of penny
                  stock rules), the NASD has adopted rules that require that in recommending
                  an investment to a customer, a broker-dealer must have reasonable
                  grounds
                  for believing that the investment is suitable for that customer.
                  Prior to
                  recommending speculative low priced securities to their non-institutional
                  customers, broker-dealers must make reasonable efforts to obtain
                  information about the customer’s financial status, tax status, investment
                  objectives and other information. Under interpretations of these
                  rules,
                  the NASD believes that there is a high probability that speculative,
                  low
                  priced securities will not be suitable for at least some customers.
                  The
                  NASD requirements make it more difficult for broker-dealers to
                  recommend
                  that their customers buy our common stock, which may limit your
                  ability to
                  buy and sell our stock and may cause the price of shares of our
                  common
                  stock to decline.

      Risks
        Related to Our Financial Condition, page 4

      TNT
        Has Yet to Attain Profitable Operations and Because TNT Will Need Additional
        Financing to Fund the Development of Business, TNT May Experience Difficulty
        in
        its Efforts to Continue as a Going Concern, page 4

              4.

                You
                  disclose that a going concern paragraph has not been issued in
                  that TNT
                  currently has adequate cash on hand for your current monthly operating
                  expenses which are nominal. We note that your cash balance has
                  decreased
                  significantly from the date of your audited balance sheet. In that
                  regard,
                  please advise us whether or not TNT still has enough cash on hand
                  to cover
                  monthly operating expenses for the next twelve months. Revise this
                  risk
                  factor and your discussion of liquidity on page 16 as
                  necessary.

      The
        disclosure in the risk factor and the plan of operations have been revised
        relative to TNT’s existing cash balance and monthly operating
        expenses.

      TNT
        is
        a development stage company with no revenues to date and there can be