LAW OFFICES OF
                           DERENTHAL & DANNHAUSER LLP
                               LAKE MERRITT PLAZA
                        1999 HARRISON STREET, 26TH FLOOR
                            OAKLAND, CALIFORNIA 94612
                                 (510) 350-3070
                           FACSIMILE: (510) 834-8309

                                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:

     This letter is in response to your  comment  letter  dated  August 22, 2008
commenting on the  above-referenced  filing. The Company is concurrently  filing
Amendment No. 1 to its Schedule TO-I.

     The following responses are numbered to correspond to the numbered comments
in your letter.

     1. The Company's shares are not publicly traded,  but are held of record in
the names of individual shareholders and are represented by certificates held in
the possession of the individual  shareholders.  It is the Company's  experience
that  the  documents   tendering  shares  are  often  incomplete  or  incorrect.
Accordingly,  though the Company will strive to determine  the pro ration factor
as quickly as possible, the Company may (but will not necessarily) require up to
ten  days to  communicate  with  tendering  shareholders  in  order  to  resolve
outstanding  documentation  issues and assure the accuracy and  completeness  of
their  documentation  before it can calculate pro ration and pay for the shares.
The Company could simply reject any incomplete or defective  tender,  effect pro
ration and make payment more  promptly,  but believes that a diligent  effort to
resolve  documentation will result in the most fair process for the shareholders
who have limited, if any,  alternative sources of liquidity for their shares. As
there is no market for the  shares,  such a limited  delay  should not cause any
adverse consequence to a shareholder.




Peggy Kim, Esq.
September 9, 2008
Page 2 of 2


     2. See the  Supplement to Offer filed as Exhibit  (a)(2) to Amendment No. 1
to the Schedule TO, under "Tender Offer - Source and Amount of Funds."

     3. The Company did not intend to incorporate information not yet filed, but
only to alert  shareholders to the information not yet available at the time the
Company was required to respond to the initial  tender offer  referred to in the
Schedule.  However,  the information in the Company's  quarterly  report on form
10-QSB  for  the  quarter  ended  June  30,  2008  has  now  been  filed  and is
incorporated  by reference into the Offer.  See the Supplement to Offer filed as
Exhibit  (a)(2) to  Amendment  No. 1 to the  Schedule TO under  "Tender  Offer -
Incorporation by Reference."

     4. See the  Supplement to Offer filed as Exhibit  (a)(2) to Amendment No. 1
to the  Schedule  TO,  which is being  disseminated  along  with the  Letter  to
Shareholders  filed  as  Exhibit  (a)(3).  The  Company  has also  extended  the
expiration  date of the Offer to  September 29 to assure  adequate  time for the
shareholders to review the updated information.

     Also filed  concurrently  and  included  with this  response  letter is the
letter from the Company with the requested representations.

     Please  contact  the  undersigned  with any further  questions  or comments
concerning this filing.

                                    Very truly yours,

                                    /s/ PAUL J. DERENTHAL

                                    Paul J. Derenthal

cc:      Michael Rider