NETGURU, INC.
                            22700 SAVI RANCH PARKWAY
                              YORBA LINDA, CA 92887
                            TELEPHONE (714) 974-2500

                                 August 10, 2005

VIA FACSIMILE AT 202 772-9210 AND EDGAR CORRESPONDENCE

Mr. Daniel Lee
Securities & Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549

         RE:      NETGURU, INC.
                  ACCELERATION OF THE EFFECTIVE DATE
                  REGISTRATION STATEMENT ON FORM S-3
                  FILE NO. 333-124920

Dear Mr. Lee:

         netGuru, Inc. ("Company") hereby requests, pursuant to Rule 461(a) of
Regulation C, that the above-referenced Registration Statement be declared
effective at 5:00 p.m. Eastern time on Friday, August 12, 2005 or as soon as
practicable thereafter.

         The Company confirms that it is aware of its responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they
relate to the proposed public offering of the securities specified in the
above-referenced Registration Statement and acknowledges that:

   o     should the Securities and Exchange Commission ("Commission") or 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 filing;

   o     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 filing; and

   o     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.

                                       Very truly yours,

                                       NETGURU, INC.

                                       By: /s/ Bruce K. Nelson
                                           -----------------------------------
                                           Bruce K. Nelson,
                                           Chief Financial Officer