From: Eric Nickerson, Controller
LGA Holdings, Inc.
3380 N El Paso St. Ste G
Colorado Springs, CO 80907
January 20, 2009
To: Patrick Gilmore
Accounting Branch
Division of Corporate Finance
Securities and Exchange Commission
Washington, D.C. 20549
Re: File No. 000-18113
Dear Mr. Gilmore,
In further response to the comments in your letter to us of December 10, 2008, please note this additional clarification of my response to the first bullet point of your Comment #3 in my letter to you of 7 January 2008:
We confirm that our management is responsible for establishing and maintaining adequate internal control over financial reporting, as such term is defined in Exchange Act Rules 13a-15(f) and 15d-15(f). Under the supervision and with the participation of our management, including our Chief Executive Officer and Chief Financial Officer, we conducted an evaluation of the effectiveness of our internal control over financial reporting as of June 30, 2008 based on the guidelines established in Internal Control — Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Based on the results of this evaluation, our management has concluded that our internal control over financial reporting was effective as of June 30, 2008 to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external reporting purposes in accordance with generally accepted accounting principles.
We intend to include disclosures similar to the above in our future filings of Form 10KSB/A.
Sincerely,
/s/ Eric Nickerson
Eric Nickerson
Controller