SecProbe.io

June 10, 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 letter dated Ma y 30, 2011 in connection with the above-
referenced filings and have the following commen ts.  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 may have addi tional comments.  Unless otherwise noted, where
prior comments are referred to they re fer to our letter dated May 20, 2011.
            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. We note your proposed disclosures in prior comment 1 to provide management’s report
on internal controls over fi nancial reporting (“ICFR”).  Your proposed disclosures for
changes in ICFR should mirror the requireme nts of Item 308(c).  In this regard, you
should disclose whether or not there were any changes in IC FR during the fourth quarter
ended December 31, 2010 that has materially affected, or is r easonably likely to
materially affect, your ICFR.  Please provide  us with your propose d, revised disclosures
in response to this comment with marked changes.

Andrew Brabin TouchIT Technologies, Inc. June 10, 2011
Page 2

2. Your response prior comment 2 references your response to prior comment 1.  However,
your response to prior comment 1 does not indicate why you believe your failure to
perform or complete your report on ICFR would not impact your conclusion on the
effectiveness of your disclosure controls and procedures as of December 31, 2010.  In
this regard, please note that, as discu ssed in Question 115.02 of our Compliance and
Disclosure Interpretation for Regulation S-K located at http://www.sec.gov/divisions/corpf in/guidance/regs-kinterp.htm
, the failure to file
management's report on Internal Control ove r Financial Reporting rendered your annual
report materially deficient and also rendere d the Company not timely or current in its
1934 Exchange Act Reporting.  In light of these facts, we do not believe you could
conclude that your disclosure c ontrols and procedures were effective as of the end of the
fiscal year.  Please revise  management's conclusion on the effectiveness of your
disclosure controls and proce dures to be that they were ineffective or tell us why you
believe such revision is not considered necessary.

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