April 9, 2009

Mr. Ethan Horowitz
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE
Washington, D.C. 20549


Re: Item 4.01 Form 8-K Filed April 3, 2008 transmitted by FAX

Dear Mr. Horowitz

We are responding to the comments of the staff (the "Staff") of the Securities
and Exchange Commission (the "Commission") to the above- referenced staff
communique sent via fax.

We have filed an amended a 8-KA which incorporates your comments.

Form 8-K filed April 3 2008

Item 1. Paragraph 2, Has been revised in part to include statement that:....
("Gruber") audited Nascent's financial statements for the fiscal year ended
December 31, 2007...

Item 2. Paragraph 3, Has been revised in part to include statement that...
Nascent resulted from the principal accountant which audited Nascent's financial
statements for the fiscal year ended December 31, 2007, decision to not to stand
for reelection for the fiscal year ending December 31, 2008.

Item 3. Paragraph 4, Has been revised in part to include statement that an
insert except for and also inserted ...Additionally, Report of the Independent
Registered Accounting Firm for the fiscal year ended December 31, 2007 contained
the following disclosure. ..." For 2007 Gruber did not audit the financial
statements of Pasani S.A. DE C.V. or Grupo Sur Promociones De Mexico, S.A. De
C.V. or Comercial Targa, S.A. De C.V. all wholly owned subsidiaries, whose
statements reflect total assets constituting 33% of the related consolidated
totals. Those statements were audited by other auditors, whose report has been
furnished to Gruber, and in their opinion, insofar as it relates to the amounts
included for Nascent Wine Company, Inc., is based solely on the report of other
auditors.

Item 4. Letter from the former Independent Public has been included as EXHIBIT
16 to the 8-KA filing.

Additionally, the Company acknowledges that:

         o        The Company is responsible for the adequacy and accuracy of
                  the disclosure in the filing;

Page 2


         o        Staff comments or changes to disclosure in response to staff
                  comments do not foreclose the Commission from taking any
                  action with respect to the filing; and

         o        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 Sates.

If you need additional clarification please contact me.



Cordially,

/s/ Sandro Piancone
-------------------
Sandro Piancone
Chief Executive Officer
Nascent Wine Company, Inc.