August 9, 2010

Via FACSIMILE
Securities and Exchange Commission
Mail Stop 4561
450 Fifth Street, N.W.
Washington, D.C. 20549

Attention: H. Christopher Owings, Assistant Director Angie Kim, Staff Examiner

RE:  HIDDEN LADDER, INC.
     AMENDMENT NO. 5 TO REGISTRATION STATEMENT ON FORM S-1
     FILED MARCH 25, 2010
     FILE NO. 333-165685

Mr. Owings/Ms. Kim:

         This letter responds to comments of the Staff (the "Staff") of the
Securities and Exchange Commission (the "Commission") contained in the letter
from the Staff to Hidden Ladder, Inc. (the "Company") dated June 22, 2010
regarding the above-referenced Registration Statement on Form S-1 (as amended)
(the "Registration Statement").

         For your convenience, we have included each of the Staff's comments
before each of the Company's responses. References in this letter to "we," "our"
or "us" mean the Company as the context may require.

STAFF COMMENT 1:

Please update your financial statements and related financial information
throughout your filing. Please see rule 8-08 of Regulation S-X.

RESPONSE:

We concur with the Staff and have the financial information in the registration
statement to be in compliance with Rule 8-08 of Regulation S-X.

STAFF COMMENT 2:

We note your response to comment three in our letter dated July 9, 2010 and the
related revisions in your filing stating that the $25,000 raised from this
offering "will be allocated 1/3 toward product development, 1/3 toward
marketing, and the remaining toward manufacturing." We further note statements
throughout your filing that none of the offering proceeds will be used toward
product development or manufacturing and that the proceeds from this offering
will be used to complete your business and marketing plan. Please clarify or
revise. Should the proceeds raised from this offering be allocated toward the
product development and manufacturing component of your business plan, please
clearly and consistently state so.

RESPONSE:

We concur with the Staff and have updated the use of proceeds section to clearly
state the proceeds from this offering will be used only to complete the business
and marketing plan. None of the proceeds will be used for product development or
manufacturing.

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STAFF COMMENT 3:

We note your response to comment four in our letter dated July 9, 2010 and the
related revisions in your filing. Please re-include the language in this section
that your auditor's have questioned your ability to continue as a going concern
as we believe it is important for readers to be reminded of this fact or tell us
why you believe this disclosure is unnecessary.

RESPONSE:

We concur with the Staff and have added the going concern disclosure.

         We trust that you will find the foregoing responsive to the comments of
the Staff Comments. Please direct any comments or questions regarding this
letter or the Registration Statement to the undersigned at 530-409-0453.

Sincerely,

/s/ David Johnson

David Johnson
Chief Executive Officer

Enclosure

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