[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



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