STI GROUP, INC.

30950 Rancho Viejo Road, #120

San Juan Capistrano, CA 92675

April 10, 2008

VIA EDGAR AND FAX: (202) 772-9210

Securities and Exchange Commission

Division of Corporate Finance

100 F Street N.E.

Washington, DC 20549

Attention: Mark Schuman

Re:	STI Group, Inc. (the "Company")
	Registration Statement on Form S-1
	(File No. 333-142911)

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the Company hereby requests that the effective date of the above-captioned Registration Statement be accelerated so that the Registration Statement may become effective at 4:00 p.m. Eastern Daylight Time, on Monday, April 14, 2008, or as soon thereafter as practicable.

In connection herewith, the Company hereby acknowledges that:

• Should the Securities and Exchange Commission (the "Commission"), or the Commission’s staff, acting pursuant 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 relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• The Company may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the deferral securities laws of the United States.

Sincerely,

STI GROUP, INC.

By: /s/ David Walters            

David Walters

Chief Executive Officer