Hall Tees, Inc.
7405 Armstrong
Rowlett, Texas 75088
(214) 883-0140
October 17, 2008
Mr. John Reynolds
Ms. Dana Brown
Ms. Raquel Howard
U.S. Securities & Exchange Commission
100 F Street NE
Washington, DC 20549
RE: Hall Tees, Inc.
Form S-1
File No. 333-150829
Dear Mr. Reynolds, Ms. Brown and Ms. Howard:
Following are responses to your comment letter dated June 6, 2008.
General
Related Stockholder Matters
| 1. | We have provided disclosures required by Item 201 of Regulation S-K, as appropriate. |
Outside Front Cover Page of the Prospectus
| 2. | We have stated that the funds will not be held in a trust account (page 1) |
Prospectus Summary
| 3. | The 10,000 share amount in this section is correct. The ‘Plan of Distribution’ section has been changed to agree with this section (page 2) |
Plan of Distribution
| 4. | We have added a risk factor discussing the risk of not having and escrow agreement for the funds we raise (page 6) |
Description of Business
| 5. | We have discussed the markets we serve in greater detail (page 13) |
| 6. | We have discussed the distribution of our products in greater detail (page 11) |
| 7. | We have disclosed the names of our major suppliers (page 14) |
| 8. | We have stated the founding date for Hall Tees & promotions, LLC (Hall Tees Texas) (page 11) |
| 9. | We have described the control persons for Hall Tees Texas and Hall Tees Nevada prior to the combination (page 11) |
| 10. | The combination agreement has been filed as an Exhibit |
| 11. | The date of formation for Hall Tees, Inc. has been corrected (page 12) |
Description of Property
| 12. | The nature of our interest in the property at 7405 Armstrong, Rowlett, Texas has been clarified (page 14) |
Management’s Discussion and Plan of Operations
| 13. | We have provided an expansion of our plan of operation as required by Item 101(a)(2) of Regulation S-K (page 16) |
| 14. | Liquidity and capital resources has been discussed (page 15) |
| 15. | The changes in financial condition has been discussed (page 15) |
| 16. | Seasonal aspects of our business have been discussed (page 17) |
| 17. | We have provided a greater detail discussion of our results of operations (page 16) |
| 18. | We have described what “our President’s industry contacts” means (page 16) |
Directors, Executive Officers and Significant Employees
| 19. | We have discussed the sourcing of products through ASI and PPAI in our Description of Business section (page 12) |
| 20. | We have indicated all positions and offices held by William Lewis (page 17) |
| 21. | We have disclosed the name and place of business of the company Mr. Lewis had before starting Hall Tees, Inc. (page 17) |
Remuneration of Directors and Officers
| 22. | This section has been revised to update the disclosure per Item 402 of Regulation S-K (page 18) |
Interest of Management and Others in Certain Transactions
| 23. | Greater detail regarding the loans from Mr. Lewis to the company has been added (page 18) |
| 24. | Mr. Lewis’ loan agreement has been filed as an Exhibit |
Principal Shareholders
| 25. | The address of each beneficial holder has been added (page 18) |
Consolidated Financial Statements
| 26. | A currently dated consent has been included with this filing |
| 27. | William Lewis was in the print business as a sole proprietor and liquidated his business in 2007. This included liquidating/selling over eighty percent (80%) of the equipment that he had and has changed his focus from performing a wide variety of services and/or products to narrowing those offered. In accordance with Section 405 of Regulation C, the sole proprietorship operated by Mr. Lewis does not represent a predecessor company since that the major portion of the business assets were sold and business liquidated, prior to starting Hall Tees, Inc. |
Part II
Unregistered Securities Issued or Sold Within One Year
| 28. | The entity ‘Hall Tees Concrete’ was a typographical error – it should read ‘Hall Tees & Promotions’ |
Exhibits
| 29. | We have included an Exhibit of subsidiaries |
| 30. | We have refiled Exhibits 2.1 and 3.1 so that they can be read more easily. |
| 31. | Our legality opinion has been revised. |
Please call me if you need any further clarification on any of these answers.
Sincerely,
/s/ William Lewis
William Lewis
President
