SecProbe.io

Mail Stop 3561
April 29, 2009
 Jennifer H. Jarvis President and Chief Executive Officer K-Kitz, Inc. 1630 Integrity Drive East Columbus, OH 43209
Re: K-Kitz, Inc.
Registration Statement on Form S-1 Filed April 6, 2009
   File No. 333-158426

Dear Mr. Jarvis:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise 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 deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.
Please understand that the purpose of our re view 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.
 Registration Statement Facing Page

1. We note that you have not marked the box indicating that the s ecurities are being
offered on a delayed or continuous basis pursuant to Rule 415.  However, from a description of the offeri ng, it appears that you are o ffering the securities on a
delayed or continuous basis.  If so, pl ease check the box for Rule 415.  Otherwise,
explain to us why your offering is not a delayed or continuous offering under Rule 415.

Jennifer H. Jarvis
K-Kitz, Inc.
April 29, 2009 Page 2  Front Cover of Prospectus

2. Please revise to leave the date of the pr ospectus at the top of the cover page
undated as that date should be the date of the effectiveness of the registration
statement.  Alternatively, please remove this date reference as one already appears at the bottom of the page.
3. Throughout your prospectus, pl ease revise to clarify that the 180-day offering
time period begins upon effectiveness of th is registration statement.  Though you
provide this disclosure in some places in your registration statement, please
ensure that you have provided it throughout.
4. In an appropriate place in your prospect us, please disclose to shareholders how
you will advise them that you have extended the offer for 90 days, should you choose to do so.  Your disclosure on pa ge 24 would seem to indicate that you will
file a post-effective amendment in the event the offering is extended.
5. We note the disclosure that you will promptly return funds held in escrow if the
minimum offering amount is not met within the specified period of time, as required by Exchange Act Rule 10b-9.  We have taken the position that "promptly" means the next business day or as soon as possible after the offering's
termination.  Revise to disclose this requirement.

We use a small number of suppliers for our products, and rely on them for prompt
shipment and quality control, page 6

6. Please eliminate the disclosure indicati ng that you have never experienced any
difficulty with the quantity or quality from your product suppliers since it mitigates the point of the risk.  Alternatively, delete the risk altogether if it does not pose a material risk of which investors should be made aware.
 Our technology and know-how is unpatented and others may seek to copy it without
compensating us, page 6

7. This risk factor indicates that you do not patent your “technology or other know-
how developed by [you] relating to [y ]our decontamination chambers or
pumps…”  Please revise your Business di scussion to explain how you contribute
technology to the products you sell.  Your disclosure on page 17 indicates that
you purchase all of your products from th ird party sources and that you custom
design and assemble your kits for re sale but it makes no mention of any
technology or other know-how that you have developed.  Pl ease revise or advise.

Jennifer H. Jarvis
K-Kitz, Inc.
April 29, 2009 Page 3  Finra sales practice requirement  may limit a stockholder’s abil ity to buy or sell our stock,
page 7

8. Please revise this risk fa ctor to avoid using the term “penny stock” as many
investors may be unfamiliar with this term .  Alternatively, refer readers to your
expanded discussion of this term that  appears later in your prospectus.
Use of Proceeds, page 9

9. Pursuant to Item 504 of Re gulation S-K, your applicati on of proceeds table should
indicate how the net  proceeds of the offering will be utilized.  Accordingly, please
revise your use of proceeds table and related discussion.  Although you disclose
that the registration costs will be paid from cash on hand, net proceeds must reflect the direct offering costs.

10. Please disclose that the two offering s cenarios presented ar e for illustrative
purposes only and the actual amount of proceeds received, if any, may differ.
 Determination of Offering Price, page 10

11. Please revise to clearly disclose how you determined the offering price.  The
existing disclosure states that it was arbi trarily determined but you then disclose
four factors.  Please clarify how the four  factors you cite c ontributed to your
offering price determination.
 Dilution of the Price You Pay For Your Shares, page 10

12. We have reviewed your dilution disclosu res and have the following comments:

• Tell us how you calculated the December 31, 2008 pre-offering net tangible
book value of $60,143.  Since it appears you do not have any intangible assets
recorded as of your fiscal year-end, pl ease clarify why your equity balance of
$35,578 does not represent net tangible book value.

• Please note that you should reflect the $39,000 of estimated offering costs as a
reduction to post-offering net tangible  book value.  Accordingly, it appears
post-offering net tangible book value assuming 100% of the shares are sold
would be only $61,000 greater than the pre-offering amount.

• Please revise your disclosures under each o ffering scenario to clearly disclose
the net tangible book value per share before the offering, pro forma net tangible book value per share after the offering, the in crease in net tangible
book value per share attributable to new investors, and dilution per share to
new investors.

Jennifer H. Jarvis
K-Kitz, Inc.
April 29, 2009 Page 4

• It appears that the “Price per share” line item at the top of your table on page
11 represents the net tangible book value per share after the offering.  Please
revise this line item description as it could easily be confused with the price
per share of the offering.

• Considering you disclose on page 10 th at your existing affiliated stockholder
paid $45,000 for 4,500,000 shares of co mmon stock, please clarify how you
determined the $16,868 amount included in the “Capital contribution of
existing stockholder” line item.

Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 12

13. We note your disclosure, “We undertake no obligation to update and revise any
forward-looking statements or to publicly  announce the result of any revisions to
any of the forward-looking statements in this document to reflect any future or
developments.”   Please revise your statem ent to include a statement to the effect
that you do not undertake the obligation to  update your forward statements except
to the extent required by federal securities laws.

14. Where you identify intermediate causes of changes in your operating results, also
describe the reasons underlying the in termediate causes.  For example, you
indicate that the increase in  your cost of sales percentage from fiscal year 2007 to
2008 is due to greater volume from your contract with the Fr anklin County, Ohio
Board of Health and you indicate that se lling, general and admi nistrative expenses
remained at consistent levels despite more than doubling your sales.  Please
explain why increased volumes with th at specific customer led to reduced
margins and why SG&A expenses and operating income remained constant despite a significant increase in sales.  A discussion of the relevant factors and
trends that led to the cha nges in cost of sales, SG&A expenses, and other income
statement line items would be beneficial to a reader.  In pa rticular, your MD&A
should include descriptions and amounts of:
• Matters that are expected to have a ma terial impact on future operations but
that have not had an impact in the past;

• Matters that have had a material im pact on reported operations but are not
expected to have an impact  upon future operations, and;

Jennifer H. Jarvis
K-Kitz, Inc.
April 29, 2009 Page 5
• Matters that have had a material impact  on past operating results and involve
prospective effects.
See SEC Release No. 33-8350.

15. Where you describe business reasons that contributed to a material change in a
financial statement line item between peri ods, please quantify, where possible, the
extent to which each factor contributed to the overall change in that line item.  For
example, with respect to the change in revenue from fiscal year 2007 to 2008,
please quantify the extent to which the ch ange is attributable to greater volume
from your contract with the Franklin C ounty, Ohio Board of Health.  See Item
303(a) of Regulation S-K and SEC Release No. 33-8350.
 Liquidity and Capital Resources, page 14

16. We note your indication that your principa l capital resources have historically
been provided through advances from Jennifer Jarvis.  Revise to quantify how much she has provided and the terms pur suant to which she has provided these
resources.  If she has loaned you money, please discuss the terms of the loan(s)
and provide applicable disclosure un der Certain Relationships and Related
Transactions, on page 22, pursuant to Item 404 of Regulation S-K.
 Recent Accounting Pronouncements, page 16

17. Although you should have already adopted  the recent account ing pronouncements
disclosed in this section, your disclosure s indicate that management either does
not expect adoption to have a material im pact on your financial statements or that
management is still evaluating the eff ect adoption will have on your financial
statements.  If true, please conf irm that you adopted these accounting
pronouncements within your historical fi nancial statements and revise your
disclosures accordingly.
 Business, page 17

18. Please revise this discussion to elab orate upon how you intend to generate
revenues from sales of your kits.  For example, explain how school systems and
municipalities have accounted for a majo rity of your revenues; in doing so,
discuss how they became your customers, the likelihood that they will generate any revenues as a result of  refill and/or replacement sales and how you intend to
identify new customers and whether you expect your new customers to constitute
school systems and municipalities.  We note your indication that you “intend to
implement an extensive marketing plan  to reach the maximum number of
potential customers to grow demand;” pl ease provide additiona l detail about your
extensive marketing plan.

Jennifer H. Jarvis
K-Kitz, Inc.
April 29, 2009 Page 6  Executive Officer Compensation, page 20

19. We note that, notwithstanding the fact th at you have no compensation to disclose,
your Summary Compensation Table does not appear to reflect the implementation
of the new disclosure requirements rela ting to executive compensation.  Refer to
Securities Act Releases 8732A and 8765 and Question 7 of the “Executive
Compensation and Related Person Disclosu re Transition Questions and Answers”
located at our web-site at www.sec.gov.   Please revise accordingly.

Plan of Distribution and Te rms of the Offering, page 24
20. Please alert investors at the beginning of this section that there is currently no
market for any of your shares, and that  you cannot give any assurance that the
shares offered will have a market value, or  that they can be resold at the offered
price if and when an active secondary market might develop, or that a public
market for your securities may not be sust ained even if developed.  Please provide
similar disclosure on page 27, where you discuss the timeframe for purposes of
obtaining a trading symbol.
21. You state that an extension of the offering period beyond 180 days will entitle
investors to a refund of their investment .  Clarify whether your option to extend
the offering for 90 days will trigger this provision.
 Description of Securities, page 28

22. You indicate here that stockholders are permitted to vote their shares
cumulatively and yet the company’s Ce rtificate of Incorporation makes no
mention of such rights.  Please revise or advise.
 Balance Sheet, page F-3

23. You disclose in Notes 7 and 9 that you redeemed the 100 common shares outstanding as of December 31, 2008 during January 2009 and issued 4,500,000 common shares to your CEO.  Please include a pro forma balance sheet as of December 31, 2008 presented along side of th e historical balance sheet that gives
effect to this change in capitalizatio n and excludes the effects of the offering
proceeds.  Please also present pro form a EPS computations on the face of your
income statements for the fiscal years presented that give effect to the 4,500,000 shares issued to your CEO.

Jennifer H. Jarvis
K-Kitz, Inc.
April 29, 2009 Page 7  Notes to Financial Statements, page F-7

 Note 5. Provision for Income Taxes, page F-12

24. Please revise your footnote to include all of the income tax disclosures required by paragraphs 43-49 of SFAS 109.  In doing so, we note that you have a deferred
tax asset line item on your balance sheet but  there is no deferred tax expense or
benefit reflected in your income tax expens e or, as described in paragraph 28(a) of
SFAS 95, as a reconciling item on your statements of cash flows.
 Note 8. Related Party Transactions, page F-15

25. As required by Rule 4-08(k) of Regulat ion S-X, please identify and state the
amounts of your related party transactions on the face of the consolidated balance
sheets, income statements, and/or statements of cash flows.
***
As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional
comments after reviewing your amendmen t and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Act of 1933 and that they have  provided all information investors require
for an informed investment decision.  Since the company and its management are 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.
Notwithstanding our comments, in the even t 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 purs uant to delegated authority, declare the
filing effective, it does not foreclose th e 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 relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

Jennifer H. Jarvis
K-Kitz, Inc. April 29, 2009 Page 8  ‚ th