GIDDY-UP PRODUCTIONS, INC. 409-903 19th Avenue SW Calgary, Alberta T2T 0H8 tel: (403)399-6402 fax: (866)900-0582 January 20, 2008 Amanda McManus Branch Chief Securities and Exchange Commission Division of Corporation Finance 100 F Street N.E. Washington, D.C. 20549 Re: GIDDY-UP PRODUCTIONS INC. REGISTRATION STATEMENT ON FORM SB-2 FILED DECEMBER 14, 2007 FILE NO. 333-148076 Dear Ms. McManus: In connection with the above-captioned filing, we are filing with the Commission, via Edgar, the following documents relating to the registration of Common Stock: A. Pre-Effective Amendment No. 1 to our Registration Statement on Form SB-2 (the "Registration Statement"); and B. Four copies of the Registration Statement, marked to indicate the changes made by Pre-Effective Amendment No. 1. The Registration Statement has been amended to respond to the Staff's letter of non-accounting and accounting comments dated January 4, 2007. Our responses to the Staff's comments are set forth below in the following paragraphs numbered to correspond to the comments in the Staff's letter. Any capitalized terms used in this letter shall have the meanings ascribed to them in the Registration Statement. Signatures 1. In response to the Staff's comment, we have revised the signature page to include the position of principal accounting officer. Should the Staff need additional information or have questions concerning our response, please do not hesitate to contact us. Yours very truly, /s/ Zoltan Nagy Zoltan Nagy President & CEO Enclosures