WHIFFLETREE ACQUISITION CORPORATION 215 Apolena Avenue Newport Beach, California 92662 ---------- Email: CassidyLaw@aol.com Telephone: 202/387-5400 Fax: 949/673-4525 October 5, 2012 October 5, 2012 Securities and Exchange Commission Division of Corporation Finance Washington, DC 20549 Re: Whiffletree Acquisition Corporation Registration Statement on Form 10 File No. 000-54724 To the Securities and Exchange Commission: Whiffletree Acquisition Corporation (the "Company") has filed with the Securities and Exchange Commission (the "Commission") its registration statement on Form 10(the "Registration Statement"). In regard to the Registration Statement, the Company and its management acknowledge that: The Company is responsible for the adequacy and accuracy of the disclosure in the filing; The comments of the Staff of the Securities and Exchange Commission or changes to the disclosure in response to such 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. Sincerely, WHIFFLETREE ACQUISITION CORPORATION By: James M. Cassidy President