SecProbe.io

Mail Stop 4561

February 11, 2008

Mark DeFoor President and Chief Executive Officer Title Starts Online, Inc. 7007 College Boulevard, Suite 270 Overland Park, KS 66211
 Re: Title Starts Online, Inc.
  Registration Statement on Form SB-2   Filed February 4, 2008    File No. 333-149036

Dear Mr. DeFoor:
  This is to advise you that a preliminary revi ew of the above registration statement indicates
that it fails in numerous material respects to co mply with the requirements of the Securities Act of
1933, the rules and regulations under that Act, and the requirements of the form.  For this reason, we
will not perform a detaile d examination of the registration st atement, and we will not issue any
comments other than those provided below becaus e to do so would delay the review of other
disclosure documents that do not appear  to contain comparable deficiencies.
 Form SB-2

 1. We note that you have not in cluded any financial statements in your registration statement.
Filings on Form SB -2 must contain current, audited fi nancial statements that include a
signed and dated report of an independent ac countant.  See Item 31 0 of Regulation S-B.

* * * * *
  You are advised that we will  not recommend acceleration of  the effective date of the
registration statement and that, sh ould the registration statement become effective in its present
form, we would be required to consider what re commendation, if any, we should make to the
Commission.   We suggest that you cons ider submitting a substantive amendment to correct the
deficiencies or a request for wit hdrawal of the filing.  Upon receipt of a re sponse to our comments
above and an amended registration statement, we will review the registration statement and may
have additional comments at that time.

Mark DeFoor
Title Starts Online, Inc. February 11, 2008 Page 2   We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes all information require d under the Securities Act
of 1933 and that they have provided all informati on investors require for an informed investment
decision.  Since the company and its management  are in possession of a ll facts relating to a
company’s disclosure, they are responsible for the accuracy and adequacy of  the disclosures they
have made.
Notwithstanding our comments, in the event the company requests acceleration of the
effective date of the pending registration statement,  it should furnish a letter, at the time of such
request, acknowledging that:
• should the Commission or the staff, acting pursua nt to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with respect to the
filing;
 • the action of the Commission or the staff, acting pursuant to delegated authority, in declaring
the filing effective, does not re lieve the company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and
 • the company may not assert staff comments and th e declaration of effectiveness as a defense
in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divisi on of Corporation Finance in connection with
our review of your filing or in response to our comments on your filing.
 If you have any questions regarding these comm ents, please contact Evan S. Jacobson at
(202) 551-3428.  If you require further assistance  you may contact me at (202) 551-3735.  If you
thereafter require further assist ance, you may contact the Assistant Director, Barbara C. Jacobs,
at (202) 551-3730.
     S i n c e r e l y ,          Mark P. Shuman      B r a n c h  C h i e f  –  L e g a l
    cc: Via Facsimile (312) 454-0261

 Bartly J. Loethen, Esq.  Synergy Law Group, LLC