CORRESP 2 filename2.txt Correspondence LAW OFFICE OF GARY A. AGRON 5445 DTC Parkway, Suite 520 Greenwood Village, Colorado 80111 Telephone: (303) 770-7254 Facsimile: (303) 770-7257 gaa@agronlaw.com July 27, 2009 Securities and Exchange Commission 100 F Street N.E. Washington, D.C. 20549 RE: Retrospettiva, Inc. Form 10-K for Fiscal Year Ended December 31, 2008 Filed April 15, 2009 File Number 001-13101 Attn: Raquel Howard Dear Ms. Howard: In response to the Staff's comment letter dated May 8, 2009 in connection with Retrospettiva, Inc. (the "Company"), please be advised as follows: 1. We will amend our Form 10-K to indicate that in Management's opinion, our disclosure and controls were not effective as of the end of the period covered by the report (December 31, 2008). 2. We will include a statement in all future filings in substantially the form set forth in the Staff's comment 2 to us. 3. We will file a Form 8-K changing our accountants from AJ Robbins, PC to Schumacher & Associates, Inc.. Our amended Form 10-K and our Form 8-K will be filed over Edgar within ten (10) business days from the date of this letter. Very truly yours, /s/ Gary A. Agron ----------------- Gary A. Agron