[OTTO LAW GROUP LETTERHEAD] July 25, 2005 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 29549-0510 Attention: Andrew Schoeffler Re: Nannaco, Inc. (the "registrant") Form 10-KSB/A for the year ended September 30, 2004. Dear Sirs: In response to your comment letter dated July 19, 2005, the registrant has filed Form 10-KSB/A incorporating its proposed revisions. Very truly yours, /s/ Tracy M. Shier ------------------ Tracy M. Shier Page 1