SecProbe.io

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April 28, 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
      Amendment 1 filed March 17, 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. We note your response to our previous comment one and repeat
the
comment in part.  If you believe that you do not fall within the
definition of a blank check company, appropriate disclosure should
be
included in your prospectus to demonstrate your status as a non-
blank
check company, including the assurance of the company`s intention
not
to enter into a merger or acquisition.  Please also include a
specific plan for implementing such business plan.

2. We note your response to our previous comment two.  We note
that
on page 19 of the initial SB-2 filing filed on January 13, 2005,
you
state that 2,000,000 shares of common stock were outstanding on
December 31, 2004.  In amendment one, on page 20, you state that
3,200,000 shares were outstanding on February 28, 2005.  In
amendment
one, in the Recent Sales of Unregistered Securities section, you
state that the company further sold 1,200,000 shares of common
stock
to its directors and officers on December 31, 2004.  We note that
this transaction was not disclosed in the initial registration
statement.  Please explain why neither the additional 1,200,000
shares outstanding nor the transaction involving the company
selling
the 1,200,000 shares to its officers and directors was disclosed
in
the initial registration statement.  In addition, please explain
why
the interim statements of operations for the three months ended
December 31, 2004 reflect the weighted average number of shares
outstanding as 2,000,000 shares.  We may have further comments.

Back Cover Page of Prospectus

3. Please provide the dealer prospectus delivery language required
by
Item 502(b) of Regulation S-B.

Prospectus Summary

4. We repeat in part our previous comment six.  Please briefly
describe the business operations since October 1, 2004.  Please
describe whether the company has begun receiving and developing
photos through its website on the internet.

5. We note the statement that "[w]e provide primarily digital
photography photofinishing through our website.  Information
contained on our website does not form part of this prospectus."
Please include the company`s website address.  Please clearly
disclose whether the company`s website is fully operational or at
what stage of development.

6. We note the statement that "[o]ur business plan for the next 12
months is to improve our website to make easier for our customers
to
use our website for photofinishing."  Please disclose the first
steps
of your proposed business plan.  Please revise to discuss whether
your website is fully operational and, if not, whether it is
likely
to be fully operational in the next 12 months.

7.  We note the statement that the company`s business plan is "to
have about 60 corner stores in the Calgary and San Francisco areas
to
participate in our website photofinishing operations."  Please
provide a reasonable basis for the statement or delete.

8. Please clarify that the net loss is for the three month period
ending December 31, 2004 or provide the net loss since inception
which may be more helpful to investors.

Risk Factors

9. In risk factor one, please clarify that the net loss is for the
three month period ending December 31, 2004 or provide the net
loss
since inception which may be more helpful to investors.  Please
include that the company currently does not have enough cash to
fund
operations for the next twelve months.

10. In risk factor two, please do not include an amount of revenue
which is not reflected in the financial statements.  In addition,
please include whether the company has begun to receive and
develop
any photos from its website.

11. In risk factor three, we note the statement that "[t]he legal
system regarding civil liabilities in China is very different from
that in the United States."  Please describe whether it would be
difficult for an investor to enforce civil liabilities against an
officer or director in China.

12. We repeat in part our previous comment 16.  In risk factor
six,
we note that the company discusses that operations may be
disrupted
by technological or other problems.  Please discuss whether the
company`s website is fully operational.

13. In risk factor nine, please discuss which director and officer
is
involved in other business activities and describe such other
business activities.  Please discuss the amount of time per week
this
director or officer intends to devote to the company.

Directors, Executive Officers, Promoters and Control Persons

14. We repeat in part our previous comment 23.  Please discuss
whether Mr. Wu still owns the online store selling Chinese CDs and
the moving company in Japan.  If not, please explain why. Also
include any amount of time per week which he devotes to these
other
companies.  Please describe whether he is a full-time graduate
student and explain how he spends the other 70% of his working
hours.

Description of Property

15. Please discuss the principal terms of the lease agreement for
the
company`s office in China.

Description of Business

16. Please confirm supplementally that the company has received
orders from corner stores whereupon the company has provided
digital
photography photofinishing to such corner stores through the
company`s website.  The company may want to state clearly how the
company has generated revenue.  Please only include the amount of
revenue if such revenue is described in the financial statements.
Otherwise, only refer to such revenues as minimal, but do not
include
the amounts.  If the company will include updated financial
statements in its next amendment, please describe the revenue in
the
Management Discussion and Analysis section.

Our Current Business

17. In this section, please clearly describe specifically whether
the
company`s website is fully operational or the current stage of
development.

18. Please explain the term "conventional film photographers" and
explain how these persons use the company`s website.

19. Please describe whether persons can currently create accounts
to
upload, store and manipulate digital images from the company`s
website and then order hard copies to be delivered in 5 business
days.  Throughout the prospectus, please clearly distinguish
between
future and current applications.

20. Please name the corner stores in Calgary, Alberta in which the
company has entered into agreements.  Please describe the
principal
terms of each agreement.

21. Please describe how a person becomes a member to use the
website.
Is this part of the website fully operational?  Does the company
have
any current members?  Do these persons pay a fee to be a member?

22. Please describe the principal terms of the agreement between
the
company and GL Photo Processing Corp.

23. We note that the company states "[w]e currently plan to charge
$1.99 per order for shipping anywhere in the U.S. and Canada."
Please describe "per order."  Also indicate the prices the company
will charge for the photofinishing.  Please clearly describe
whether
the company will take orders from customers in countries other
than
the U.S. and Canada.

24. Please discuss how the company located the Calgary corner
stores
in which it has entered into agreements.  Also discuss how it will
locate and negotiate with other corner stores in Calgary and San
Francisco.  Please describe whether the company will be the
exclusive
digital photography photofinishing company for these corner
stores.
Also indicate whether the company is currently providing these
services for the three corner stores in Calgary.

Marketing

25. Please provide a reasonable basis for the statement "we
provide
services with cheaper price than supermarket stores and
wholesalers."
Has the company performed a market study?  Is the company
referring
to supermarket stores and wholesalers in the U.S. or Canada?  If
you
cannot provide a reasonable basis, the statement should be
removed.

26. In general, some of the information in the business section
appears promotional, rather than factual, and should be revised to
remove all promotional statements.  We refer, for example, to the
reference "we plan to aggressively promote our website."  Please
revise accordingly.

27. Please specifically describe the national newspapers and
magazines.  We note that the company discloses in the MD&A section
that it will allocate only $5,000 to $7,500 for marketing during
the
next twelve months.  Please disclose any research the company has
performed regarding advertisements through these mediums and the
reasonable basis that the company would be able to use such
mediums
for the amounts described during the next twelve months.  We also
note that the company is uncertain whether it has these funds or
if
it will need to raise additional capital.  Some of the statements
may
be promotional in nature and may need to be removed.

28. Please specifically describe the "free search engine traffic
and
listings."

29. Please describe the "major search engines."

Technology

30. Please discuss the principal terms of the agreement between
the
company and Instaspace Technologies.  Please describe the recourse
for the company in the case of Instarspace`s failure to provide
the
"100% uptime guarantee."  Also, describe whether the company
currently pays Instarspace Technologies $500 a month.

Competition

31. Please describe the competitive business conditions and
company`s
competitive position in the industry.  Please further describe the
methods of competition such as price and whether the company`s
orders
will be priced lower than those of other similar companies.
Please
include the reasonable basis for any comparisons.  See Item
101(b)(4)
of Regulation S-B.

Growth Strategy

32. Please describe the online advertisement.

33. Please describe the trade shows that the company intends to
participate.

34. Please describe the websites in which the company intends to
establish as "website affiliates."  Has the company entered into
any
such arrangements?  If yes, please describe or provide the
reasonable
basis for the statement.

Management`s Discussion and Analysis and Plan of Operations
Plan of Operations

35. We repeat our previous comment 57.  Please describe the
company`s
plan of operations for the next twelve months as required by Item
303(a) of Regulation S-B.  Provide details of your specific plan
of
operations, including detailed milestones, the anticipated time
frame
for beginning and completing each milestone, the estimated
expenses
associated with each milestone and the expected sources of such
funding.  Please explain how the company intends to meet each of
the
milestones if it cannot receive funding.  See Item 303(a)(1) of
Regulation S-B.

Cash Requirements

36. Please discuss how long the company can satisfy its cash
requirements.  See Item 303(a)(1)(i) of Regulation S-B.

Other

37. Please discuss any expected significant changes in the number
of
employees.  See Item 303(a)(1)(iv) of Regulation S-B.

Executive Compensation

38. We repeat our previous comment 62.  Please clearly describe
whether any compensation will be paid by the company to any
officer
for the current year.

Financial Statements
Unaudited Interim Financial Statements
Interim Balance Sheets, page 42

39. We noted that you recorded share subscriptions receivable from
a
director at December 31, 2004.  Please tell us supplementally, and
disclose in Note 3 (share subscriptions receivable, page 46) when
the
receivable was paid in cash.  Please note that if the receivable
has
not been paid prior to the publication of your financial
statements,
the staff would expect such amounts to be presented as contra
equity.
Please refer to SAB Topic 4E.

Interim Statements of Operations, page 43

40. We noted that the weighted average shares outstanding at
December
31, 2004 was 2,000,000 shares; however, your disclosure on page 5
(Summary Financial Data) indicates 1,469,388 weighted average
shares
outstanding.  Please revise this inconsistency.

Part II
Exhibits

41. Please include executed copies of the agreements for exhibits
10.3 and 10.4.

Closing Comments

      As appropriate, please amend your 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 response 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.

      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 Angela Halac at (202) 551-3398 or Hugh West
at
(202) 551-3872 if you have questions regarding comments on the
financial statements and related matters.  Questions on other
disclosure issues may be directed to Thomas Kluck at (202) 551-
3233
or Mike Karney, who supervised the review of your filing, at (202)
551-3847.

						Sincerely,

						John Reynolds, Assistant Director
						Office of Emerging Growth Companies

cc:	Ailin Wan
	Fax (604) 689-9773
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Thrifty Printing, Inc.
April 28, 2005
Page 1

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