VITAS GROUP, INC.
ITALIA #32-81 Y MARIANA DE JESUS
QUITO, EC 170102 ECUADOR
Tel. 011-59302-6000404
Email: vitasgroup@gmail.com
November 7, 2011
Mr. Max A. Webb
Assistant Director
U.S. Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Re: Vitas Group, Inc.
Amendment No.3 to
Registration Statement on Form S-1
Filed on October 13, 2011
File No. 333-175590
Dear Mr. Webb:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Vitas Group, Inc. (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form S-1/A to 9:00 a.m. Eastern Daylight Time on Thursday, November 10, 2011, or as soon thereafter as is practicable.
The Company acknowledges the following:
· Should the Commission or the 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 staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Thank you for your assistance.
Sincerely,
/S/ Irina Tchernikova
Name: Irina Tchernikova
Title: President, Treasurer and Secretary (Principal Executive, Financial and Accounting Officer)
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