CIENEGEA CREEK HOLDINGS, INC
                          9181 S ANTLER CREST DR.
                             VAIL, AZ 85641

March 23, 2009

U.S. Securities and Exchange Commission
Washington, DC 20549

Re: 	Cienega Creek Holdings, Inc.
	Form 10-KSB for the year ended March 31, 2008
	Filed May 20, 2008, and As Amended on August 13, 2008
	File No. 0-53364


Dear Commission,

This letter shall serve as our correspondence with regard to the Commission's
comment letter dated March 9, 2009.  This is our second response and intended
to clarify our original response to Item 3 dated March 19, 2009.

Item 1) We will ensure the correct audit report date is reflected in future
filings.  We will also revise the second sentence in Risk Factors to include
the words "substantial doubt".

Item 2) We will clarify that our balance sheet, statement of operations, cash
flows and equity were all reviewed.  We will also follow Rule 8-03 of
Regulation S-X regarding review reports.

Item 3) We will expand the Results of Operation section to discuss the
operating results for the year-to-date period as compared to the prior year
comparative period as per Item 303(b)(2) of Regulation S-K.

Item 4) We will use the exact wording in Exhibit 31(i) of Item 601 of
Regulation S-K in our Certifications of the Chief Executive Officer and Chief
Financial Officer.


We are aware of our filing obligations and intend to fully comply therewith.
We also make the following representations:

1) the company is responsible for the adequacy and accuracy of the disclosure
in the filings; and

2) staff comments or changes to disclosures in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

3) the company 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.


Sincerely,

/s/Michael A. Klinicki

Michael A. Klinicki
President
Cienega Creek Holdings, Inc.