NUVIM(R), INC.

                               September 26, 2007

William Thompson, Branch Chief
Securities and Exchange Commission
Mail Stop 3561
100 F Street NE
Washington, DC 20549

   Re:  NuVim, Inc
        Form 10-QSB for Fiscal Quarters Ended March 31, 2007 and June 30, 2007
        Filed May 15, 2007 and August 14, 2007
        File No. 1-32499

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Dear Mr. Thompson,

This letter is in reply to yours of September 21, 2007.

We have filed the  amendments  to the  Quarterly  Reports on Form 10-QSB for the
first and second quarters of 2007.

Item 3. Controls and Procedures

   1.   The necessary conclusions have been provided.

NuVim acknowledges that:

          .    NuVim  is  responsible  for  the  adequacy  and  accuracy  of the
               disclosure in its 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 filings; and

          .    NuVim  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 for your attention to these matters.  Please call our General Counsel,
Mark Siegel,  if additional  steps are required.  Please be advised that his fax
number is 561.862.0714 and his telephone is 561.998.6835.

                                             Respectfully submitted,

                                             NuVim, Inc.


                                             By: /s/ Richard P. Kundrat
                                                 -------------------------------
                                                 Richard P. Kundrat, Chairman &
                                                 Chief Executive Officer

Copies should be provided to:
Adam Phippen

MAS/dt