SecProbe.io

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Mail Stop 3561

							November 15, 2005

Via U.S. Mail

Mr. Steven L. White, President
Wren, Inc.
386 North 210 East
Mapleton, Utah 84664

Re: 	Wren, Inc.
	Amendment no. 1 to Form SB-2
      Filed October 17, 2005
	File No. 333-122185

Dear Mr. White:

      We have reviewed your filing 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.

      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 and 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.

Cover Page
1. Please delete the last sentences of the first paragraph.
Please
limit the information to that requested in Item 501 of Regulation
S-
B.

Prospectus Summary, page 4
2. We note your response to our prior comment 6 and your revised
disclosure.  We reissue the comment, in part.  Please revise to
also
include your revenues and net losses for the most recent audited
period and interim stub to provide a snapshot of your company.

Signatures, page 44
3. Under "in accordance with the requirements of the Securities
Act
of 1933, this registration statement was signed by the following
persons in the capacities and on the dates stated," please include
signatures for the person or persons acting in the capacities of
principal executive officer, principal financial officer and
controller and principal accounting officer, as well as at least
the
majority of the board of directors.  Refer to Form SB-2,
Signatures
and Instructions 1 and 2 to Signatures.

Legality opinion, exhibit 23.1
4. For equity securities, counsel must opine on the legality of
the
securities under the laws of the state in which the registrant is
incorporated.  It appears that your legality opinion does not
currently provide an opinion on the legality of securities under
the
laws of the state in which Wren, Inc. is incorporated.  Please
revise
your legality opinion as necessary.

Additional Information, page 22
5. Please revise the address for the public reference facility
where
investors may examine your filing to 100 F Street, NE, Room 1580,
Washington, DC 20549.

Other
6. In the event of delay in effectiveness of the Form SB-2, please
update the financial statements in accordance with Item 310(g) of
Regulation S-B.

* * * * *

      As appropriate, please amend the registration statement in
response to these comments.  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 supplemental information.
Detailed cover 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 filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that

* Should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* The action of the Commission or the staff, acting pursuant to
delegated authority in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* The company may not assert this action 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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

We direct your attention to Rules 460 and 461 regarding requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

      You may contact Patrick Kuhn at (202) 551-3308 or Michael
Fay,
the Branch Chief - Accountant, at (202) 551-3812 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact Johanna V. Losert at (202) 551-3325 or me
at
(202) 551-3210 with any other questions.

      Regards,

      Susan Block
							Attorney-Advisor

cc:	Cletha A. Walstrand, Esq.
	via facsimile: 801-363-8512
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Steven L. White
Wren, Inc.
November 15, 2005
Page 4 of 4

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