SecProbe.io

CORRESP
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corresp

July 29, 2005

VIA EDGAR AND FACSIMILE

Mr. Kurt Murao, Attorney-Advisor

Securities and Exchange Commission

Division of Corporate Finance

450 Fifth Street NW

Washington, D.C. 20549

              Re:

    Baby Universe, Inc. (the“Company”)

Registration Statement on Form S-1, as amended

File Number 333-124395

Dear Mr. Murao:

     Pursuant to Section 8 of the Securities Act of 1933, and Rule 461 thereunder, GunnAllen
Financial, Inc. and Webush Morgan Securities Inc., as the managing underwriters, hereby join the
Company in requesting acceleration of effectiveness of the above-referenced registration statement
for August 2, 2005 to 4:30 p.m., Eastern time, or as soon thereafter as practicable. In connection
with the foregoing, GunnAllen Financial, Inc. and Wedbush Morgan Securities Inc. hereby acknowledge
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;

    •

    We are aware of our responsibilities under the Securities Act of 1933 and the
Securities Act of 1934 as they may relate to the proposed initial public offering of
the securities referred to in the above-referenced registration statement; and

    •

    Neither GunnAllen Financial, Inc. nor Wedbush Morgan Securities Inc. may assert this
action as defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

     Copies of the Preliminary Prospectus dated July 13, 2005 have been or will be made available
in sufficient time for distribution to all prospective purchasers no less than 48 hours before it
is expected confirmations will be mailed. GunnAllen Financial, Inc. and Wedbush Morgan Securities
Inc. will comply with Rule 15c2-8 under the 1934 Act.

     In connection with the foregoing, please be advised that GunnAllen Financial, Inc. and Wedbush
Morgan Securities Inc. have effected approximately the following distribution of copies of the
Preliminary Prospectus dated July 13, 2005:

    GunnAllen Financial and Wedbush Morgan offices

    1,785

    Individuals, corporations and other entities

    6,675

     Please confirm the date and time of effectiveness of the registration statement to Carrie Long
at Foley & Lardner LLP, our counsel, at 813-225-4177.

    Very truly yours,

GunnAllen Financial, Inc.

    By:
    /s/ Dean Tanella

    Dean Tanella, Executive Vice President

    Wedbush Morgan Securities, Inc.

    By:

/s/ Michael Gardner

    Michael Gardner, CFA

    Executive Vice President