Penola Inc.
                                492 Gilbert Road
                           West Preston, Victoria 3072
                                    Australia
                             Tel: +61 (3) 9605 3907

                                October 12, 2011

VIA EDGAR

Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Attention: Anne Nguyen Parker, Esq.


                                   Penola Inc.
                            Registration Statement on
                         Form S-1 (File No. 333-175529)

Dear Ms. Parker:

     Pursuant to Rule 461(a) of the Securities Act of 1933, as amended, Penola
Inc. (the "Company") hereby requests that the effective date of the
above-captioned Registration Statement on Form S-1 of the Company be accelerated
to October 12, 2010 at 5:00 p.m. E.S.T. or as soon thereafter as may be
practicable.

     The Company hereby acknowledges that:

     *    should the Commission or the staff of the Commission (the "Staff"),
          acting pursuant to delegated authority, declare the filing effective,
          it does not foreclose the Commission from taking any action with
          respect to the Registration Statement;

     *    the action of the Commission or the Staff, acting pursuant to
          delegated authority, in declaring the filing effective, does not
          relieve the Company from its full responsibility for the adequacy and
          accuracy of the disclosure in the Registration Statement; and

     *    the Company may not assert Staff comments and the declaration of
          effectiveness as a defense in any proceeding initiated by the
          Commission or any person under the federal securities laws of the
          United States.

     We understand that the Staff will consider this request as confirmation by
the Company of its awareness of its responsibilities under the federal
securities laws as they relate to the issuance of the securities covered by the
Registration Statement. If you have any questions regarding the foregoing,
please contact the undersigned at +61 (3) 9605 3907.

                                     Very truly yours,


                                     By: /s/ Filomena Gencarelli
                                        -------------------------------------
                                     Name:  Filomena Gencarelli
                                     Title: President

cc: Thomas E. Puzzo, Esq.