October 26, 2010



United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 7010
Washington, DC  20549

Attention:  Mrs. Mindy Hooker

Re:     Vital Products, Inc.
        Form 8-K
        Filed 10/8/2010
        File Number: 333-127915


Dear Mrs. Hooker

Set forth below is the Company's response to the Staff's comments.  The
numbering of the response corresponds to the numbering of the comment in the
letter from the Staff.

Comment 1

Please amend your filing to follow the language in Item 304(a)(2) of
Regulation S-K and state whether during the registrant's two most recent
fiscal years (disclose specific years) and any subsequent interim period
through the date of resignation (actual date of change) there were any
consultations with your new auditor.  We note your current disclosure only
includes one fiscal year.


Response 1

We have amended the 8-K as requested


Comment 2

To the extent that you make changes to the Form 8-K to comply with our
comments, please obtain and file an updated Exhibit 16 letter from the
former accountants stating whether the accountants agree with the statements
made in you revised Form 8-K


Response 2

We have amended the 8-K as requested


The Company acknowledges:

* the company is responsible for the adequacy and accuracy of the disclosure
  in the filing;

* 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

* the company may not assert staff comments as a defense in any proceeding
  initiated by the Commission or any person under the federal securities law
  of the United States.


If you have further questions or comments, please feel free to contact us or
our counsel.  We are happy to cooperate in any way we can.


                                        Regards,

                                        /s/ Michael Levine, CEO