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                            February 10, 2023

       John Morgan
       Chief Executive Officer
       Nitches, Inc.
       1333 N Buffalo Dr., Suite 210
       Las Vegas, NV 89128

                                                        Re: Nitches Inc.
                                                            Amendment No. 2 to
                                                            Offering Statement
on Form 1-A
                                                            Filed January 26,
2023
                                                            File No. 024-12029

       Dear John Morgan:

             We have reviewed your amended offering statement 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 by amending your offering statement
and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
November 10, 2022 letter.

       Form 1-A/A filed January 26, 2023

       Our Business, page 6

   1.                                                   We note your response
to comment 8 and reissue in part. Please disclose where
                                                        geographically the
manufacturers the Company has relationships with are located and any
                                                        risk factors associated
therewith.
       Executive Compensation, page 38

   2.                                                   Please update your
compensation disclosure to reflect the fiscal year ended August 31,
                                                        2022.
 John Morgan
Nitches, Inc.
February 10, 2023
Page 2
General

3.       We note your responses to comments 1 and 2. Please confirm that you
have ceased all
         activities/initiatives involving NFTs other than in regards to OVS.
Please also explain
         your ongoing role(s) relating to the POM project and the related POM
NFTs, including
         any fees that you are entitled to in connection with resales.
       You may contact Melissa Gilmore at 202-551-3777 or Hugh West at
202-551-3872 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alex King at 202-551-8631 or Asia Timmons-Pierce at 202-551-3754 with
any other
questions.



FirstName LastNameJohn Morgan                                 Sincerely,
Comapany NameNitches, Inc.
                                                              Division of
Corporation Finance
February 10, 2023 Page 2                                      Office of
Manufacturing
FirstName LastName