SecProbe.io

May 20, 2011
 Via E-mail

Andrew Brabin Chief Financial Officer TouchIT Technologies, Inc. 12 Sirdar Road Rayleigh, Essex  UK, SS6 7XF
Re: TouchIT Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed March 31, 2011 File No. 333-151252

Dear Mr. Brabin:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended December 31, 2010

 Item 9A. Evaluation of Disclo sure Controls and Procedures

 Management’s Annual Report on Internal C ontrol Over Financial Reporting, page 18

 1. You indicate that your management has not pe rformed its assessment of internal control
over financial reporting as of December 31, 2010 due to “a transition period established
by rules of the Securities and Exchange Commission for newly public companies.”

However, pursuant to Item 308T of Regulati on S-K, beginning in fi scal periods ending
on or after December 15, 2007, companies must f ile management’s assessment of internal
control over financial reporting if they prev iously filed an annu al report with the
Commission for the prior fiscal  year.  If your management has not yet performed its
assessment, we ask that you complete your evaluation and amend your filing within 30

Andrew Brabin TouchIT Technologies, Inc. May 20, 2011
Page 2

calendar days to provide the required ma nagement's report on internal control over
financial reporting since you have been public beginning on June 10, 2008 and filed an
annual report for fiscal 2009.  In perfor ming your evaluation, you may find the following
documents helpful:

ƒ the Commission’s release Amendments to Rules Regarding Management’s Report on
Internal Control Over Financial Reporting  (Securities Act Release 8809/Financial
Reporting Release 76).  You can find this release at:
http://www.sec.gov/rules/final/2007/33-8809.pdf
;
ƒ the Commission’s release Commission Guidance Regarding  Management’s Report on
Internal Control Over Financial Reporti ng Under Section 13(a ) or 15(d) of the
Securities Exchange Act of 1934 (Securities Act Releas e 8010/Financial Reporting
Release 77).  You can find this release at http://sec.gov/rule s/interp/2007/33-
8810.pdf ; and
ƒ the “Sarbanes-Oxley Section 404 – A Guid e for Small Business” brochure at:
(http://www.sec.gov/info/smallbus/404guide.shtml ).
 Please note that the failure to perform ma nagement’s assessment adversely affects the
Company’s and its shareholders ability to av ail themselves of rules and forms that are
predicated on the current or timely filing of Exchange Act reports.  For further
information regarding these impacts, please see Compliance and Disclosure Interpretation
115.02, which you can find at http://www.sec.gov/divisions /corpfin/guidance/regs-
kinterp.htm .
 2. In addition, please consider whether manageme nt’s failure to perform or complete its
report on internal control over financial repo rting impacts its conclusions regarding the
effectiveness of your disclosure controls and pr ocedures as of the end of the fiscal year
covered by the report and revise you r disclosure as appropriate.
 Independent Auditors Report, pages F-1 and F-21

3. Please revise to file auditors’ reports that  reference the two year  period ended December
31, 2010, as the current reference does not indicat e that the financial statements for both
fiscal 2010 and 2009 were audited.
4. Additionally, please confirm whet her or not the audit was c onducted in accordance with
the standards of the Public Company Acc ounting Oversight Board (United States) and
revise the auditors’ reports to indicate as such pursuant to PCAOB Auditing Standard No.
1.  The reference to conducting the audit in  accordance with “International Standards”
should be removed.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are

Andrew Brabin TouchIT Technologies, Inc. May 20, 2011
Page 3

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.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Melissa Feid er at (202) 551-3379 if you have questions regarding
comments on the financial statements and relate d matters.  Please contact me at (202) 551-3499
with any other questions.
Sincerely,  /s/  Kathleen Collins

Kathleen Collins Accounting Branch Chief