BellaVista Capital, Inc.
                              15700 Winchester Blvd
                          Los Gatos, California 950301

                                September 9, 2008



BY EDGAR AND FACSIMILE

Peggy Kim, Esq.
Special Counsel
Office of Mergers & Acquisitions
Division of Corporation Finance
Mail Stop 3628
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-3628

          Re:      BellaVista Capital, Inc. (the "Company")
                   Schedule TO-I filed August 18, 2008
                   SEC File No. 5-80316

Dear Ms. Kim:

     The Company filed an Amendment No. 1 to the above-referenced  Schedule TO-I
concurrently with filing this letter. The Schedule has been revised as requested
in your letter dated August 22, 2008.  Under separate cover,  our counsel,  Paul
Derenthal,  has  responded  on behalf of the  Company  to the  comments  in your
letter.

     The Company hereby acknowledges with respect to the above referenced matter
that

     o    the  Company is  responsible  for the  adequacy  and  accuracy  of the
          disclosure in this filing;

     o    staff  comments or changes to disclosure in response to staff comments
          in the filings  reviewed by the staff do not foreclose the  Commission
          from taking any action with respect to the filing; and

     o    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.

                  BellaVista Capital, Inc.

                  By:  /s/ MICHAEL RIDER
                       ------------------------------
                       Michael Rider, President