SecProbe.io

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Mail Stop 3561

      July 19, 2005

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

      Re.	Thrifty Printing, Inc.
   Registration Statement on Form SB-2
      Amendment No. 2 filed June 9, 2005
   File No. 333-122005

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.  Please note that the page numbers
referred to below refer to the numbering of the non-EDGAR marked
copy.

1. Please briefly describe the company`s operations or
developments
from January 23, 2004 to October 1, 2004.

2. We note that the company has undertaken/is undertaking several
private placement offerings contemporaneously with this offering.
Please provide an explanation as to how these private placements
can
be undertaken simultaneously with this offering and consistently
with
the requirements (including but not limited to the requirement
prohibiting general solicitations) of the federal securities laws.
We may have further comment.

3. We note the statement that the company "commenced operations on
October 1st, 2004."  Please reconcile this statement with the
disclosure in the financial statements that the company has not
earned any revenues.
4. We note the statements that "[w]e have completed our website
and
have begun receiving and developing photos. . . . It [website] has
been fully operational since February 2005."  Please reconcile
these
statements with the disclosure in the financial statements that
the
company has not earned any revenues.

5. We note the statement that "[o]ur head offices are located at
3702
South Virginia . . . Reno, Nevada."  Please reconcile this
statement
with the disclosure in risk factor three that all of our assets
and
all of our directors and officers are outside of the United
States"
and the disclosure in the description of business section that the
business administration is conducted in China.

6. We note the statement that "[w]e are a development stage
company
and have only generated a limited amount of revenue since our
inception on January 23, 2004."  Please reconcile this statement
with
the disclosure in the financial statements that the company has
not
earned any revenues.

Summary of Financial Data, page 5

7. Please revise your table to remove the period from January 23,
2004 (date of inception) to December 31, 2004, and replace with
the
applicable date for the six months ended March 31, 2005.

Risk Factors, page 6

8. In risk factor one, we note the statement that "we received an
aggregate of $24,000 gross proceeds from another private placement
financing in March 2004."  Please clarify when this private
placement
was completed.

9. In risk factor two, we note that the company has deleted the
statement that "[w]e . . . have only generated revenue in the
amount
of $5,150.23 as of February 28, 2005."  We also note the statement
that "[w]e have begun to receive and develop photos form our
website
and have only generated minimal revenue."  Please reconcile these
statements with the disclosure in the financial statements that
the
company has not earned any revenues.

Directors, Executive Officers, Promoters and Control Persons, page
18

10. Please include the names of the online store selling Chinese
CDs
and of the moving company that was started by Mr. Wu.

Description of Business, page 22

11. We note the statements "[w]e . . . commenced business
operations
. . . generated minimal revenue."   Please reconcile these
statements
with the disclosure in the financial statements that the company
has
not earned any revenues.

Our Current Business, page 22

12. We note the statement "[t]his part of the website is fully
operational."  Please explain whether there are parts of the
website
that are not fully operational.

13. Please explain whether the company has taken orders from
registered members and generated any revenues from such orders.

14. We note your statement that "[w]e currently plan to charge
$2.99
per order for shipping anywhere in the U.S. and Canada. . . . no
matter how many prints are in the order."  Please advise how the
company can only charge $2.99 an order for delivery to anywhere in
the U.S. or Canada if, for example, a person orders hundreds of
large
prints?  Please explain the shipping charges to the company by the
China Post EMS.  We note that most carriers, such as the U.S.
Postal
Service and FedEx, appear to charge per size of the order and by
time
of delivery.  Please explain.  We may have further comment.

15. We note the statement "[i]n total a customer`s order may take
up
to 7 business days for home delivery."  Please explain the
delivery
process of the China Post EMS and the charges to the company per
time
of delivery.  We may have further comment.

16. We note the statement that "[w]e give corner stores of our
dealer
network unique price chart."  Please explain whether the prices
charged by the company to corner stores are less than the prices
charged to customers via the company`s website.

17. Under the subsection "Employees," please describe whether the
two
associates that are Mr. Wu Pei Ru`s relatives are employees of the
company.

18. Please describe whether the company has begun receiving orders
from corner stores that entered into dealer agreements with the
company.

Marketing, page 23

19. We note the statement "free listings on search website
directories like Google and Yahoo."  Please explain.

Technology, page 24

20. We note the disclosure that Mr. Yu Wan currently pays the $500
monthly fee to Instaspace Technologies on behalf of the company
and
that the company will reimburse him later.  In the section
"Certain
Relationships and Related Transactions," please describe all funds
loaned by Mr. Yu Wan to the company and the conditions of
repayment.
See Item 404(a) and (d) of Regulation S-B.  In addition, to the
extent that such an agreement by and between the company and Mr.
Yu
Wan is evidenced in writing, provide disclosure of all material
provisions of such written agreements and include it as an exhibit
to
this registration statement.
Competition, page 24

21. In the comparisons of price, please include costs of shipping.
We may have further comments.

22. Please explain "50% off of regular price."

23. We note the comparison of the company to Kodak and Sony.
Please
explain the differences in financial positions and resources
between
the company and Kodak or Sony.

Management`s Discussion and Analysis and Plan of Operations, page
27

Plan of Operations, page27

24. We noted from your disclosures on page 4 (our business) and
page
27 that you have begun receiving and developing photos and have
generated limited revenues.  It is not clear to us where your
revenues have been recorded in your financial statements.  In this
connection, please revise your financial statements and critical
accounting policies (page 31) to include your policy for revenue
recognition.  Address each of the criteria in SAB 104 and EITF 99-
19
in your response and revised disclosure.   We may have additional
comments.

25. As applicable, please revise the statement of "minimal
revenues"
in light of the disclosure in the financial statements.

26. On pages 28 and 27, we note the disclosure that "he needs to
pick
up the order by himself after 5 business days."  Please explain.

27. On page 28, please remove the promotional statement that
"[t]he
corner stores we contacted all appeared very happy to work with
us."

28. On page 28, we note the statement "[t]hey are working for us
at
no cost in their spare time right now, but we will negotiate their
compensation after the Company becomes profitable."  Please
explain
whether the two associates will be compensated later for their
current work.

29. On page 28, we note the statement "increase in photofinishing
sales."  Please explain if the company has had any sales.

30. We note that in the "Plan of Operation," the estimated costs
for
the next twelve months appear to be from $40,000 to $60,000.
Please
reconcile this amount with the disclosure in the "Prospectus
Summary"
that discloses the costs to be between $25,000 and $30,000, in
risk
factor one that discloses the costs to be between $25,000 and
$30,000
and under the subsection "Cash Requirements," in the table, that
discloses the costs to be between $25,000 and $36,000.

Cash Requirements, page 29

31. In the table on page 30, please reconcile the line item costs
with those costs described in the "Plan of Operations."  For
example,
in the plan of operations we note website costs of $15,000 and in
the
table these costs are $5,000 to $7,500.  Also, in the plan of
operations we note the hiring of local representatives for $10,000
and of marketing specialists for $10,000 to $30,000 whereas in the
table it is unclear how theses costs are accounted for.

32. In describing the costs in the table for the next twelve
months,
please include legal costs.

Unaudited Interim Financial Statements

Interim Financial Statements for December 31, 2004

33. Please remove these interim financial statements as unaudited
interim financial statements in a registration statement are
required
for the most recent fiscal quarter, in this case, the six months
ended March 31, 2005.  Please refer to the guidance in Item 310(b)
of
Regulation SB.

* * * * *

      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

cc:	Ailin Wan
	Fax (604) 669-5791
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Mr. Yang Wu,
Thrifty Printing, Inc.
July 19, 2005
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