SecProbe.io

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Mail Stop 6010

								August 30, 2005

Luiz Augusto Brasil
Chief Executive Officer
Nitar Tech Corp.
3950 Worthview Place
Mississauga, Ontario
Canada L5N 6S7

	Re:	Nitar Tech Corp.
		Form SB-2 filed August 4, 2005
		Form SB-2, Amendment 1 filed August 19, 2005
		File No. 333-127170

Dear Mr. Brasil:

	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 information so we
may
better understand your disclosure.  After reviewing this
information,
we may 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 any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

FORM S-1

General

1. On your website, you state the information on the website and
emails distributed through the website "may contain forward-
looking
statements within the meaning of The Private Securities Litigation
Reform Act of 1995 (the `Act`), as well as Section 27A of the
Securities Act of 1933 and Section 21E of the Securities Exchange
Act
of 1934."  You also state these statements "are intended to
identify
forward-looking statements within the meaning of the Act and are
subject to the safe harbor created by the Act."  Please delete
these
statements from your website and any other communications you
make.
The safe harbor does not apply to forward-looking statements made
by
companies which issue penny stock, or in connection with an
initial
public offering.  You issue penny stock, and your company is
currently
in the process of an IPO.  See Sections 27A(b)(1)(C) and (b)(2)(D)
of
the Securities Act and Sections 21E(b)(1)(C) and (b)(2)(D) of the
Exchange Act.

2. Two press releases, dated January 27, 2005 and February 7,
2005,
state your company was negotiating an acquisition of Connect
Education
Systems Inc. and doing due diligence.  Unless you have abandoned
plans
to do this acquisition, please discuss it in your filing.  Also,
please provide us your analysis as to the applicability of Rule 3-
05
of Regulation S-X regarding this potential acquisition.

3. The Standby Agreement terms appear to indicate that you will
not be
able to request advances until the shares are listed or quoted on
the
Bulletin Board, NASDAQ, or a named exchange.  However, throughout
the
prospectus, you state or imply that advances are permitted even if
your stock is quoted only in the Pink Sheets.  We note the
disclosure
on pages 14 and 15, and in the risk factors.  Please revise or
advise.

4. Please include the information required by Item 304 of
Regulation
S-B or state in the filing if not applicable.

5. It appears from footnote 4 to the January 31, 2005 financial
statements (page 31) and footnote 5 to the April 30, 2005
financial
statements (page 40) that you have had some related party
transactions
during the last two years.  Please include a section containing
the
information required by Item 404 of Regulation S-B.  See Item 19
of
Form SB-2.  You should also file as exhibits the agreements
underlying
the transactions.  See Item 601(b)(10)(i)(A) of Regulation S-B.

Registration Statement Cover Page

6. In footnotes 4 and 5 to the fee table, you state that the
shares of
common stock offered are "to be issued" to the selling
stockholders.
Supplementally, please confirm to us that these shares have been
issued and were outstanding as of the date you filed the
registration
statement.

Prospectus Cover Page

7. You state that the offering is expected to terminate 24 months
after the registration statement is declared effective.
Supplementally, tell us how you plan to update the information in
the
prospectus and ensure that offerees are furnished with
prospectuses
containing current information during the offering period.  Also,
confirm to us that if you file any post-effective amendment to the
registration statement that does not go effective immediately upon
filing, that all selling activity will be suspended until we
declare
each such post-effective amendment effective.

Prospectus Summary, page 5

8. Your summary does not present a balanced view of your business.
Currently, your summary is a detailed discussion of only the
positive
aspects of your company`s business, product, and strategy.  Please
revise the summary to present a balanced picture.  The revised
disclosure should identify the difficulties your business faces.
Also, since you discuss your strategy, you should also discuss the
hurdles you will need to overcome to accomplish the strategy
objectives.

9. You have not included a "Description of Business" section,
which is
required by Item 101 of Regulation S-B, but you have included a
high
level of detail about your business on pages 5-8 of your
"Prospectus
Summary."  Please note that Item 503(a) of Regulation S-B requires
that the summary be brief.  It should not contain the level of
detail
required by Item 101.  Also, Item 503(c)(2) requires that the risk
factors immediately follow the summary.  Therefore, please
substantially condense the Prospectus Summary, and include a
business
description containing all of the information required by Item 101
somewhere after the risk factors.
      In response to this comment, you might move to the Business
section the text to which some or all of our other comments on the
Prospectus Summary apply.  If you do so, please address the
comments
in the Business section.

10. 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 minimal 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 goals but
cannot state your beliefs or expectations unless you have a basis
for
such beliefs or expectations.  Please revise throughout.

11. To the extent that you discuss future marketing and
distribution
channels or strategies, state that they are in fact contemplated
and
that you are not currently engaged in or utilizing them.  Also,
state
that you do not have contracts or arrangements concerning these
potential marketing and distribution channels.  We may have
further
comments after reviewing your revised business section.

12. To the extent a segment of your business is not yet
operational,
please consider whether using the present tense is appropriate
when
discussing the Company`s activities or product offerings.  Use the
present tense only when the Company is engaged currently in an
activity.  Conversely, if you plan to engage in an activity, but
do
not engage in it currently, use the future tense.  Please revise
the
disclosure throughout the document accordingly.

Our Company, page 5

13. Please expand the "Nature of Our Business" paragraph to
explain
that even though you have applied for a patent concerning the
technology you describe and received an application number, you
have
not received a patent for the technology, your patent application
may
not be approved, and there is no guarantee that you will ever
receive
a patent for the technology.  Also, consider providing appropriate
risk factor disclosure concerning this issue.

14. Your "Business Development" and "Product Services" subsections
are
almost entirely composed of purported statements of fact for which
you
provide no substantiation.  For each such statement you make,
please
disclose any third-party sources you relied upon for support for
them,
and provide us with any copies of the underlying source material.
Copies delivered should be marked to highlight the relevant
information.  Each of these factual statements that cannot be
supported should be deleted.  We will likely have further comments
upon reviewing your supporting material and significantly revised
disclosure.

15. Consider deleting the rhetorical questions in this subsection
and
stating clearly, in Plain English, the assertions you are making.

16. We note the comparisons of Choozmail to filters on page 6.
Please
explain what a filter is, and describe the types of internet
content
that filters are designed to address.

17. Please define "POP3" and "SMTP," and clarify how Choozmail`s
not
using these servers enables parents to take control of their
children`s email messages.  Also, please define "independent
polling
routine."

18. Although the filing discusses several of Choozmail`s
advantages,
it is not clear what Choozmail is or how it works, nor is it clear
how
it enables parents to control the emails and chats in which their
children participate.  Please clearly explain what Choozmail is,
and
explain in practical language how it works.  For example, does it
route all messages to the parent`s email address, and the parent
must
give his or her approval before the message can proceed to the
child`s
email address?

19. Please state when you plan to do an infomercial, and discuss
how
far into this process you are and what, if any, progress you have
made.  For example, have you already hired a production company?
Also, disclose here and in MD&A how much you will spend to produce
and
air the infomercial.

Choozmail Direct Sales, page 7

20. In this subsection, you state what you believe large
corporations,
associations and third world countries can do with your product.
Please expand the disclosure in each of the paragraphs of this
subsection to indicate, as applicable, that none of these types of
entities use your product and service offerings or that any
current or
past use has been very limited and quantify any such limited use.

21. Please discuss your direct sales force.  How many sales
employees
do you have, and where are they located?

22. Please explain how you arrived at the estimate that 0.5% of
families have the financial ability to subscribe to Choozmail.
Clarify whether this statistic refers to U.S. customers or to
third
world countries.

23. You mention that you have signed contracts with
representatives in
countries such as Brazil and India.  For each of these contracts
that
is material, describe all of its material terms and file it as an
exhibit.  If none of the contracts to which you allude is
material, so
state and explain that they are not significant or delete
references
to them.

Business Strategy, page 8

24. You should expand the list of strategies to explain exactly
how
you plan to accomplish each of the stated goals.  We note the more
detailed disclosure concerning these points on page 18.  You
should
state these objectives once in the prospectus, and revise each
point
of the seven-point platform to be more specific.  State how you
plan
to accomplish each of these objectives, and discuss the specific
obstacles you will need to overcome to do so.

Standby Equity Agreement, page 8

25. It appears that Yorkville Advisors, LLC and Monitor Capital
may be
underwriters.  Please advise or revise the disclosure to state
that
they are underwriters.

Summary Consolidated Financial Information, page 9

26. The results that you present here appear to be for the nine-
month
period ended April 30, 2005, not the three month period ended on
that
date.  Please revise.

27. Please provide summary balance sheet information.

Risk Factors, page 10

28. Each risk factor should consist of a one-sentence heading and
a
discussion.  The heading should summarize the risk to investors,
and
it should be underlined or bolded.  The discussion, which is
typically
approximately 1-3 paragraphs in length, should provide the
information
necessary to give investors an understanding of how the risk has
affected your company in the past and/or how it may affect the
company
in the future.  In each risk factor, you should explain the given
risk
specifically.  Please revise all risk factors accordingly.  We
expect
substantial changes will be made to this section and will have
further
comments upon your significantly revised disclosure.

29. Please consider whether additional risk factors may be
warranted
for issues such as your competition, a dependence on key
personnel,
and your dependence on one product.  Also, we note from a March 9,
2005 press release that you are selling Choozmail in Brazil.  Are
there any risks associated with expanding overseas?

Considering our financial condition you will be unable . . . ,
page 10

30. Please disclose the amount of your accumulated deficit.

Our business development is contingent upon raising debt . . . ,
page
10

31. We note the possibility that you may not be able to operate
for
the next 12 months.  Please discuss this risk in a separate risk
factor.  State how long you believe your current funds will enable
you
to remain in business, and state how long you believe the funds to
be
received from Cornell Capital will enable you to remain in
business.

Because our common stock is considered a penny stock . . . , page
10

32. Please explain what penny stock is, and briefly describe the
penny
stock rules.

There are 6,300,000 shares of our common stock held by our
officers .
. . , page 11

33. Please state the date(s) when the Rule 144 restrictions end
for
the 6.3 million shares held by officers and directors and other
affiliates.

Investors must contact a broker dealer to trade . . . , page 11

34. Please explain what a market maker is and why it is
significant
that bulletin board securities only require one market maker.

Because bulletin board and Pink Sheet stocks are usually not
followed
. . . , page 11

35. Please explain why a lack of analysts results in a lower
trading
volume, and clarify why a lower trading volume constitutes a risk
to
investors.

Use of Proceeds, page 12

36. Please describe the technology you plan to develop with the
proceeds.

37. Please identify the specific uses you describe with "general
working capital," and state how much funds you plan to allocate
for
each of these uses.

Selling Stockholders, page 13

38. Please identify the natural persons who are the beneficial
owners
of the shares held by Industrial Consultants.

39. We note your counsel, Richard S. Lane, is selling shares in
this
offering.  In an appropriate section of your document, please
include
the information required by Item 509 of Regulation S-B.  See Item
13
of Form SB-2.

40. Please move the risks on page 14 under "There are certain
risks
related to sales by Cornell Capital Partners, including:" to the
Risk
Factors section of the document.

Standby Equity Distribution Agreement, page 15

41. After the chart showing the number of shares that will be
issued
at the prices mentioned, state that if you are required to issue
more
than the 16,252,748 shares you are registering, that you will file
a
new registration statement.

Description of Property, page 18

42. Please file as an exhibit the lease agreement between Nitar
and
its President.  See Item 601(b)(10)(i)(D) of Regulation S-B.

Legal Proceedings, page 18

43. This section consists of an incomplete sentence.  Please
finish
the sentence by describing the material legal proceedings.

Management`s Discussion and Analysis or Plan of Operation, page 18

44. Please provide all of the information required by Item 303(b)
and
(c) of Regulation S-B.  See Item 17 of Form SB-2.  Currently, your
MD&A section contains none of the required disclosure.  We will
likely
have further comments once we have reviewed the MD&A you will add
in