SecProbe.io

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February 8, 2005

MAIL STOP 0511

Mr. Yang Wu, President and CEO
Thrifty Printing, Inc.
3702 South Virginia Street, #G12-401
Reno, NV 89502-6030

Re:	Thrifty Printing, Inc.
File No. 333-122005
Registration Statement on Form SB-2
      Filed January 13, 2005

Dear Mr. Wu:

      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.

      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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. Section (a)(2) of Rule 419 defines a blank check company as a
company that is issuing penny stock that is "a development stage
company that has no specific business plan or purpose or has
indicated that its business plan is to engage in a merger or
acquisition with an unidentified company or companies, or other
entity."  In discussing this definition in the adopting release,
the
Commission stated that it would "scrutinize . . . offerings for
attempts to create the appearance that the registrant . . . has a
specific business plan, in an effort to avoid the application of
Rule
419."  See Security Act Release No. 6932 (April 13, 1992).

Your disclosure indicates that you are a development stage company
that intends to be an on-line photofinishing company.  Your
disclosure also shows, that you have no assets other than cash of
$28,110, no revenues, no operations, no developed website, no
experience in the on-line photofinishing business and no full-time
employees.  We note that the company is not raising any capital in
this offering.  It is uncertain from your disclosure whether the
company will be able to implement its business plan based on the
amount of its current cash position.  It is unclear if and how the
company will raise additional capital.  Also, it appears from the
disclosure that the company may not be able to make a profit based
on
the expenses and revenues in the proposed business.  Furthermore,
we
note that the company lacks a specific plan of operations for the
next twelve months.

In view of the foregoing, it appears that your proposed business
may
be commensurate in scope with the uncertainty ordinarily
associated
with a blank check company.  Accordingly, please revise your
disclosure throughout your registration statement to comply with
Rule
419 of Regulation C or supplementally provide a detailed
explanation
as to why Rule 419 does not apply to this offering.  If you
believe
that you do not fall within the definition of a blank check
company,
appropriate disclosure to demonstrate your status as a non-blank
check company should be included in the prospectus as well as a
specific business plan.  We offer the following comments to help
you
revise your disclosure.

2. We note the registration statement covers the resale of 76% of
the
shares of common stock outstanding of Thrifty Printing, Inc. in
your
initial public offering.  Under these facts, your offering appears
to
be an "at the market offering of equity securities by or on behalf
of
the registrant" under Rule 415(a)(4) of Regulation C through the
selling security holders who appear to be underwriters under the
Securities Act.  Because Thrifty Printing, Inc. does not qualify
to
conduct an offering "at the market," please revise the terms of
your
offering to provide that all offers and sales will be made at a
disclosed fixed price for the duration of the offering, as would
be
required in a primary offering by Thrifty Printing, Inc.  Under
Rule
415(a)(1)(ix), the offering must be prompt
and continuous for the duration of the offering.  Note that
Thrifty
Printing, Inc. does not
appear to qualify to conduct a delayed offering under Rule
415(a)(1)(x).  Please expand
the disclosure to explain how the offering will be conducted in a
prompt and continuous manner.  If you disagree that the offering
should be considered a primary offering by Thrifty Printing,
please
provide your analysis supplementally.

3. In Note 1 to the financial statements, the company states
"[m]anagement has plans to seek additional capital through a
public
offering of its common stock."  We note that the company is not
seeking to raise capital in this offering.  Further, it appears
that
there is no reference in the registration statement to the company
raising capital in a public offering.  Please explain throughout
the
applicable parts of the registration statement the company`s plan
to
raise capital in relation to the disclosure in Note 1.

4. On the prospectus cover page, and throughout the prospectus,
you
make reference to getting the company`s shares listed on the OTC
Bulletin Board.  Wherever such disclosure is provided, additional
disclosure should be provided to the effect that there can be no
assurances that the company will be approved for listing on the
OTC
Bulletin Board.  We note, for example, the language in the
footnote
on page 10 of the prospectus.

Table of Contents

5. We note that most your table of contents is in all capital
letters.  All capital letters impede the readability of the
disclosure.  Instead of all capital letters, use bold face type or
italics to highlight the information.  Revise throughout the
prospectus as necessary.

Prospectus Summary

6. We note that the company states that it has commenced
operations
on October 1, 2004 and that "[w]e are an on-line photofinishing
company."  Please reconcile with the disclosure on page 21 of the
business section that "[w]e are a development stage company that
has
not commenced business operations."  If the company has begun
operations, please briefly describe such operations.

7. Please include a brief summary of your proposed business plan.
See Item 503 of Regulation S-B.

8. We note the statement that the company has not "generated any
significant revenue since inception."  Please revise to indicate
that
the company has not generated any revenues since inception.  In
addition, please include that the company has had a net loss.

9. We note the statement that "we anticipate that we will require
an
additional $25,000 to $30,000 through October, 2005."  Please
indicate whether the company has any plans to raise capital.

10. We note that the company states that "[o]ur financial
statements
contain additional note disclosures describing the circumstances
that
lead to this disclosure by our independent auditors."  Instead of
referring to the note in the financial statements, it may be more
useful for readers to summarize the note in this section.  Please
revise.

Risk Factors

11. Please revise risk factor one to focus only on the risk in the
subheading that the company has had no cash flow from operations
and
the risk to the company if it is unable to obtain future
financing.
We note that the company refers to satisfying its cash
requirements
until December 31, 2004.  Please update this information to
discuss
how the company will satisfy its cash requirements for the next 12
months.  Please include the risk to the company if it is unable to
obtain additional capital.  Does the company have a plan to raise
capital in the next 12 months?  The risks regarding unexpected
expenses, dilution and increase liabilities from commercial loans
are
separate risks.  Please revise.  In addition, the first risk
factor
states that the company`s year end is both September 30 and
December
31.  Please revise and clarify these statements here and
throughout
the prospectus as necessary.

12. You should present as risk factors only those factors that
represent a material risk to investors in this offering.  Do not
include risk factors that could apply to any issuer or to any
other
offering.  Several of your risk factors seem to fit into this
category and you should revise to cite a particular risk, or
remove
them.  For example, please see risk factors 2, 8, 10 and 21.

13. In risk factor three, it may be more useful for reader to
discuss
whether the company will likely generate revenues in the next 12
months or will it be dependent upon raising capital.

14. Risk factor four is similar to risk factor one and you may
want
to consider combining these risk factors.  You may want to specify
whether the company currently has enough funds for expanding the
website and marketing before September 30, 2005.  If not, please
explain in more detail the company`s plan for funding.  In
addition,
you should revise to remove other risk factors such as dilution
and
defaulting on future debts.

15. In risk factor five, please specify the assets.  In addition,
please specify the country, China.  It may be important to discuss
the possible difficulties for investors to enforce civil
liabilities
in China.

16. In risk factor nine, we note that the company discusses that
operations may be disrupted by technological or other problems.
We
note that the company currently does not have an operational
website.
It may be more appropriate to discuss as a risk factor, the
problems
the company may incur in developing a website.

17. In risk factor 16, regarding dilution, you may want to discuss
the company`s plan to raise additional capital and the dilutive
effect that it could have upon shareholders.

18. In the last risk factor on page 9, you mention the ability of
the
officers and directors of the company to exercise control over
minority shareholders in voting matters, although the officers and
directors beneficially own only 23.1% of the issued and
outstanding
shares of the company`s common stock.  Please expand your
discussion
to clarify how this is the case.

The Offering

19. Please describe the reference to Regulation S.

20. Please revise to clearly state that the company shares will
only
sell at prevailing market prices when quoted on the OTC Bulletin
Board or when listed on an exchange.  Please note that some
quotation
systems are not considered public markets under the Securities Act
of
1933.  See also similar disclosure on the cover page of the
prospectus and under the sections Determination of Offering Price
and
Plan of Distribution.

Determination of Offering Price

21. If applicable, please include whether the price of $.02 per
share
is based on the company`s price per share in its recent private
offering.

Selling Stockholders

22. We note that the company states that "none of the stockholders
is
a broker-dealer or an affiliate of a broker-dealer to our
knowledge."
Please describe whether the company or any of its affiliates
inquired
into whether any of the stockholders are a broker-dealer or an
affiliate of a broker-dealer.

Directors, Executive Officers, Promoters and Control Persons

23. For each officer and director, please describe all employment
during the past five years.  See Item 401(a)(4) of Regulation S-B.
In the description, please include the name and business of the
person`s employer, beginning and ending dates of employment, and
the
positions held.  Please include all current positions with other
companies.

24. Please discuss any possible conflicts of interest.

25. Please describe whether Yang Wu and Pei Ru Wu are related.
See
Item 401(c) of Regulation S-B.

Description of Property

26. We note that the company states that the head office is
located
at 3702 South Virginia Street, Reno, Nevada.  We also note that
all
of the officers reside in China and that the business
administration
and photofinishing operations are conducted at 12 Jiangsu Road,
Shanghai, China.  Please explain what operations of the company,
if
any, will be performed at the Reno, Nevada address.  Please
describe
both the Reno, Nevada address and the Shanghai, China address and
include whether the offices are used for other business purposes.
Please describe the company`s leasing or ownership arrangements
for
both the Reno, Nevada office and the Shanghai, China address.
Please
see Item 102(a) of Regulation S-B.  If the company does not have
ownership or control over the premises, please name the person
that
has ownership and control.  In risk factor 11, we note that the
company has entered into an agreement with GL Photo Processing
Corp.
for the photofinishing of the photographs.  Please explain whether
GL
Photo`s address is 12 Jiangsu Road, Shanghai, China.  If so,
please
describe what ownership or control the company has over theses
premises.  If this is incorrect, please reconcile the disclosure
regarding the location of the company`s photofinishing operations
in
the Risk Factor section and the Description of Property section.

Description of Business

27. The Description of Business section is generic and seems to
focus
on what the company intends to do into the future.  Please focus
your
discussion mainly upon current operations as further explained
below.
Please significantly expand your disclosure to address your
current
and immediate activities according to the requirements of Item
101(b)
of Regulation S-B.  Prospective operations should be discussed
under
an appropriate subheading, along with the conditions and timetable
for conducting those operations.

Our Current Business

28. Please describe the current principal products or services of
the
company and their markets as required by Item 101(b)(1) of
Regulation
S-B.  As a general matter, it is inappropriate to speak about the
merits of the company without qualifying your statements in a
manner
that makes clear to the reader that the company is in the
developmental stage and has not commenced operations.  Unless you
have demonstrable proof of a statement concerning what the company
can do or is capable of, you should not make such statements.  You
may state your objectives and/or goals but not your beliefs or
expectations unless you have a basis for such beliefs or
expectations.  Please revise throughout.

29. We note that the company states "[w]e are an on-line
photofinishing services company that provides primarily digital
photography photofinishing through our website."  The company also
states that "[w]e are a new print brokerage firm."  Please
reconcile
these statements with the disclosure that the company has not
commenced business operations.  This disclosure should be
reconciled
and revised as necessary throughout the prospectus.

30. We note the statement "[w]e established our website as an
online
photo community for both digital camera and conventional film
photographers."  Please describe whether the company has begun
developing its website or whether the website is completed.  If
the
company has begun developing the website but it is not completed,
please describe the current phase of development of the website.

31. Please revise the business section to comply with the
requirements of Rule 421 of Regulation C.  Please use definite
concrete everyday words.  In the business section, you employ
technical terms and jargon that may be confusing and difficult for
an
average reader to understand.  For example, you include terms such
as
"digital imaging technology provider," "Network member," and
"Internet infrastructure company."  Please remove unnecessary
technical terms or jargon from the body of the prospectus. Where
technical terms or jargon have to be used, please explain them in
ordinary, everyday language when first used.

32. We note that the company states that "[o]