December 6, 2004

Mail Stop 0510


Nannaco, Inc.
4906 Point Fosdick Dr., Suite 102
Gig Harbor, WA 98335
Attention: Steve Careaga

Re: 	Nannaco, Inc.
      Preliminary Information Statement on Schedule 14C
      Filed November 24, 2004
      File No. 000-50672

Dear Mr. Careaga:

      We have the following comments.  Please revise your
preliminary
information statement in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

1.	This is to advise you that a preliminary review of your
preliminary information statement indicates that it fails in
numerous
material respects to comply with the requirements of the
Securities
Exchange Act of 1934, the rules and regulations thereunder and the
requirements of Schedule 14C.  Our initial concerns are set forth
below.  For this reason, we will not perform a detailed
examination
of the information statement and we will not issue additional
comments until these matters are reconciled.  We suggest that you
consider submitting a substantive amendment correcting the
deficiencies.  Once you have done so, we will perform a more
detailed
review of your preliminary information statement.

2.	Please note that Item 1 of Schedule 14C requires that
information from Schedule 14A, including Note A thereto, be
provided
if applicable.  Since (i) consent is being sought for the reverse
stock split, (ii) these matters are being done to effectuate your
proposed merger with Nazz Productions, Inc. and (iii) security
holders will not have a separate opportunity to consent to your
proposed merger, seeking consent for the reverse stock split
represents seeking consent for your proposed merger under Note A
to
Schedule 14A.  Therefore, please provide all information required
by
Item 14 of Schedule 14A with respect to your proposed merger.  See
Item 1 of Schedule 14C and Note A to Schedule 14A.

3.	We note your disclosure regarding the issuance of shares of
common stock to Nazz Productions, Inc.  It appears that this
issuance
of securities is contingent upon consummation of the reverse stock
split.  Therefore, please provide the disclosure required by Item
11
and Item 12 of Schedule 14A with respect to this issuance.

*			*			*

      Please revise your preliminary information statement in
response to these comments.  You may wish to provide us with
marked
copies of your amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      You may contact Dale Welcome at (202) 942-2871 or Anne
McConnell at (202) 942-1795 if you have questions regarding
comments
on the financial statements and related matters.  Please contact
Andrew Schoeffler at (202) 824-5612 or, in his absence, Jennifer
Hardy at (202) 942-2864 or the undersigned at (202) 942-1950 with
any
other questions.

Sincerely,


Pamela A. Long
Assistant Director


cc:	Tracy Shier, Esq.
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Steve Careaga
Nannaco, Inc.
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

         DIVISION OF
CORPORATION FINANCE