SecProbe.io

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Mail Stop 3561
								August 1, 2005

Kenneth P. Laurent
c/o Savoy Financial Group
6767W. Tropicana Ave., Suite 207
Las Vegas, NV  89103

Re:	  New Design Cabinets, Inc.
        Amendment No. 2 to Registration Statement on Form SB-2
        File No. 333-124060
        Filed July 19, 2005

Dear Mr. Laurent:

      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.  Feel free
to
call us at the telephone numbers listed at the end of this letter.

General
1. Please refer to comment 3 in our letter dated July 11, 2005.
Paragraph 23 of  Schedule A to the Securities Act of 1933 requires
that a Section 10 prospectus disclose "the names and addresses of
counsel who have passed on the legality of the issue[.]"  Please
revise your prospectus accordingly, placing the required
information
under either an Experts or a Legal Matters section heading.  In
addition, given that the auditor is an expert for purposes of
Section
11 in connection with this offering and has properly filed a
consent
pursuant to Rule 436, it is our belief that naming the auditor as
an
expert is appropriate disclosure in the prospectus.  Please revise
your prospectus accordingly, placing the information under an
Experts
section heading.  Finally, we also again remind you to update your
table of contents, which continues to list an Interests of Named
Experts and Counsel section despite the absence of corresponding
disclosure in the body of the prospectus.

Reports to Security Holders, page 15
2. Your disclosure currently includes a reference to "MCI."  We
assume
the reference should be "NDCI."  Please revise.

Management`s Discussion and Plan of Operations, page 15
3. Please refer to comment 4 in our letter dated July 11, 2005.
Other
than revising the order of paragraphs in this section and adding
sentences about your planned website and planned marketing in the
top
two paragraphs on page 16, it does not appear you have made any
significant changes in response to the comment.  It therefore
remains
unclear what your plan of operation is for the next twelve months
and
how you intend to generate the $18,000 in revenues you state you
will
require to support ongoing operations for the next twelve months.
In
particular, as currently drafted, the plan of operation disclosure
does not appear to contain adequate information about your actual
intended products.
Please revise to provide a specific plan of operation,
particularly
addressing all supplies, materials, product costs, product
pricing,
etc. related to the prefabricated wine rack kits and custom
woodwork
products you intend to sell.  Please also revise to explain why
you
have not developed any prefabricated kit prototypes or obtained
custom
woodwork customers yet nor expect to have any for six to nine
months.
Given that you received proceeds of $36,000 from private
placements
more than six months ago and will not receive proceeds from the
pending selling shareholder offering, it is unclear why you have
not
developed any sample products or sales yet nor expect to do so for
at
least six to nine more months.
Finally, in these regards, as reflected in comment 1 of our letter
dated May 11, 2005, if you are unable to describe a specific
business
plan, then it appears you may be a blank check company within the
meaning of Rule 419 and should revise the registration statement
accordingly.

*****

      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 responses to our
comments and provides any requested 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.

      You may contact Andrew Blume, Staff Accountant, at (202)
551-
3254 or George Ohsiek, Senior Staff Accountant, at (202) 551-3843,
if
you have questions regarding comments on the financial statements
and
related matters.  Please contact Anita Karu, Attorney-Advisor, at
(202) 551-3240, David Mittelman, Legal Branch Chief, at (202) 551-
3214, or me at (202) 551-3725 with any other questions.

								Sincerely,

								H. Christopher Owings
      Assistant Director

cc:	Wendy E. Miller, Esq.
	Fax:  (949) 625-8885
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Kenneth P. Laurent
New Design Cabinets, Inc.
August 1, 2005
Page 1

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