[Kahiki Letterhead]

March 30, 2006

Mr. Karl Hiller
Branch Chief
Securities and Exchange Commission
100 F Street, N.E., Mail Stop 7010
Washington, DC 20549-7010

RE: Kahiki Foods, Inc.
    Form 10-KSB for Fiscal Year Ended March 31, 2005
    Filed June 21, 2005
    File No. 333-113925

Dear Mr. Hiller:

Thank you for your March 14, 2006 letter of comments on two filings made by
Kahiki Foods, Inc. ("Kahiki"). The comments related to Kahiki's 10-KSB for the
fiscal year ended March 31, 2005, and to Kahiki's 10-QSB for the fiscal quarter
ended December 31, 2005.

Ms. Fratianne, to whom you addressed your comments, submitted her resignation
from Kahiki on November 30, 2005, effective in mid December. Kahiki filed an 8-K
dated December 2, 2005 to announce her resignation. I was named Chief Financial
Officer of Kahiki on January 30, 2006. Kahiki filed an 8-K the same date with
that announcement.

This letter is in response to your comments. We have filed an amended 10-KSB for
March 31, 2005, and an amended 10-QSB for December 31, 2005 to include the
changes outlined herein. Our response below is keyed to the individual numbered
comments in your letter.

FORM 10-KSB FOR FISCAL YEAR ENDED MARCH 31, 2005:

Comment 1 - Management's Discussion and Analysis or Plan of Operation, Revenue
Recognition, page 8: We have amended the wording on revenue recognition in
management's discussion in the 10-KSB for March 31, 2005. We removed the
original paragraph and replaced it with the following:

"We record revenue when rights and risk of ownership have passed to our
customers, the price and terms are finalized, and collection of the resulting
receivables is reasonably assured. This generally occurs when products are
delivered to the customer. Customers do not have the right to return products
unless the products are damaged. We sometimes offer promotions or co-operative
advertising, and pay slotting fees to customers to obtain shelf space in retail
locations. All such amounts are recorded as a decrease in sales in the period
incurred."






Comment 2 - Financial Statements, Audit Opinion:
Your comment indicated that the report of the prior auditors for the year ended
March 31, 2004 was not included in the 10-KSB for March 31, 2005. We obtained
the prior auditor's permission to include their report. The report is included
in the 10-KSB/A.

Comment 3 - Financial Statements, Audit Opinion:
For the audit of March 31, 2005, the auditors have amended their report to
include the reference to the Standards of the Public Company Accounting
Oversight Board (United States). The revised report is included in the 10-KSB/A.

Comment 4 - Financial Statements, Balance Sheet, page F-2:
We have moved the negative cash balance on the March 31, 2005 balance sheet to
accounts payable in current liabilities. The change is included in the balance
sheet of the 10-KSB/A, and is also reflected in the statement of cash flows.

Comment 5 - Financial Statements, Note 5-Long Term Debt, page F-10:
We originally classified as "Current debt" a $150,000 note payable to a related
party. This was not included in the Long-Term Debt footnote. We have modified
the presentation on the March 31, 2004 balance sheet to show this note on the
same line, "Related Party Note Payable" in current liabilities, as we did for
this note at March 31, 2005. After this change, the detail in the Long-Term Debt
footnote agrees with the amount shown as current debt on the 2004 balance sheet.
The related party note payable was discussed in Note 12 Related Party
Transactions in the original filing. We have included the changes in the
10-KSB/A balance sheet.

Other changes to the Form 10-KSB for March 31, 2005:
The changes outlined above in response to your comments one through five also
required several other changes in the 10-KSB/A. Previously filed exhibit 14.1
was incorporated by reference to the original filing. We incorporated by
reference to the original filing exhibits 31.1; 31.2; and 32. In the case of
Exhibits 31.1; 31.2; and 32, both of the people who originally performed the
evaluations are no longer with the company (one of them died) and we cannot
otherwise get their current signatures. The current President (Principal
Executive Officer) has not performed reviews of internal controls as of any date
prior to his appointment as acting President (on July 26, 2005) and the current
Chief Financial Officer has not performed reviews of internal controls as of any
date prior to his appointment as CFO on January 30, 2006. We filed new consents
from both accounting firms, exhibits 23.1 and 23.2. We filed as exhibit 10.9 a
copy of the related party note payable identified above.





FORM 10-QSB FOR FISCAL QUARTER ENDED DECEMBER 31, 2005:

Comment 6 - Controls and Procedures, page 18:
We deleted the original sentence beginning "Based upon that evaluation..." in
the first paragraph of Controls and Procedures. In lieu thereof, we added the
following sentence, which addresses your concerns:

"Based on that evaluation, our President and Acting CFO concluded that Kahiki
Foods disclosure controls and procedures as of December 31, 2005 (the end of the
period covered by this Report) have been designed and are functioning
effectively to provide reasonable assurance that the information required to be
disclosed by Kahiki Foods in reports filed or submitted by it under the Exchange
Act is recorded, processed, summarized and reported within the time periods
specified in the Securities and Exchange Commission's rules and forms."

We also deleted the second paragraph of the original submission as it was no
longer necessary. The changes are included in the 10-QSB/A for December 31,
2005.

Comment 7 - Note 3-Insurance Proceeds, page 10:
Your comment requested expansion of the Liquidity and Capital Resources section
of Management's Discussion to discuss how restricted cash has been reflected in
the statement of cash flows. We have added the following commentary as a new
first paragraph to the Liquidity and Capital Resources section of Management's
Discussion in the 10-QSB/A:

"On July 22, 2005, Michael Tsao, Founder, Chairman of the Board of Directors,
President and Chief Executive Officer of Kahiki died. Kahiki had maintained key
man life insurance on Mr. Tsao. A total of $750,000 of the insurance had been
pledged as collateral on certain loans. Kahiki received that amount of proceeds
from the life insurance policies, plus interest, in the quarter ended September
30, 2005 (all of which has been treated as restricted deposits). Kahiki received
an additional $500,000 of proceeds, plus interest, in the quarter ended December
31, 2005 (all of which were used in operations). All of the proceeds are
included in other income in the accompanying unaudited financial statements.
Kahiki deposited the $750,000 proceeds with a commercial bank acting as trustee
on Kahiki's State Economic Development Revenue Bonds. Kahiki received a letter
from the Ohio Department of Development ("ODOD") indicating that the deposit is
being used to make payments to the State of Ohio on the ODOD loan to Kahiki for
the next twelve months starting with the October 2005 payment. ODOD further
indicated that the balance of the deposit will be maintained by the trustee as a
reserve to be applied toward the final loan payments. The portion of this
deposit representing payments due on the loan through September 30, 2006,
$277,126, is included in "Restricted deposits - current portion" on the
accompanying unaudited balance sheet. The remaining portion of the deposit,
$391,040, is included in "Restricted deposits" in Other Assets on the
accompanying unaudited balance sheet. On the accompanying unaudited statement of
cash flows, both restricted deposits have been excluded from the total of "Net
cash provided by (used in) operating activities" through an adjustment to "Other
assets".




Other changes to the 10-QSB for the quarter ended December 31, 2005:
The original 10-QSB had revenue recognition wording in management's discussion
similar to the wording you requested us change on the 10-KSB. We modified the
discussion in the same way as on the 10-KSB/A for March 31, 2005. We increased
net sales and cost of sales by $123,000 for the three- and nine-month periods
ended December 31, 2005 for invoiced freight discounts to a customer which were
originally subtracted from reported net sales. The discounts are more properly
shown as freight costs in cost of sales. This change resulted in minor changes
in management's discussion for percents and for reported sales and margins.
Sales and freight costs for prior periods had been reported properly.


* * * * *

We hereby acknowledge that:

* The company is responsible for the adequacy and accuracy of the disclosures in
the filings;

* Staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

* The company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.


Thank you again for your comments. Please call me with any questions. My direct
dial number is 614.322.3189.

Sincerely,

/s/ Frederick A. Niebauer

Frederick A. Niebauer
Chief Financial Officer