| Glenn & Glenn |
| Attorneys at Law |
| 124 Main Street, Suite 8 |
| New Paltz NY 12561 |
| Telephone 845.256.8031 |
| Fax: 845.255.1814 |
| rglenn@glennandglenn.com |
August 21, 2014
| John Reynolds, Assistant Director |
| Securities and Exchange Commission |
| 100 F Street N.E. |
| Washington DC 20549 |
| Re: | MITU Resources, Inc. |
| Amendment No. 1 to Registration Statement on Form S-1 | |
| Filed August 4, 2014 | |
| File No. 333-196858 |
Dear Mr. Reynolds:
We have amended our registration statement in response to your comment letter dated August 14, 2014. This letter reproduces your comment letter and identifies where the response to each of your comments is located in the amendment to registration statement or makes supplemental response where appropriate.
Emerging Growth Company, page 15
1. We note your revised disclosure in response to comment 1 of our letter dated July 14, 2014. Please revise to clarify that as an emerging growth company, you are exempt from Sections 14A(a) and (b) of the Exchange Act, rather than Exchange Act Sections 14A and 14B and Item 404(b) of Regulation S-K, rather than Item 404(b).
The requested changes have been made on page 15
Directors and Executive Officers, page 51
2. We note your revised disclosure in response to comment 20 of our letter dated July 14, 2014. Please further revise to clarify how long Mr. Rincon has held his current positions with the company.
The requested changes have been made on page 52.
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Please feel free to call me at 845.256.8031 or email me at the address set forth above should you have any further questions.
| Glenn & Glenn | |
| /s/ D. Roger Glenn |
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