SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

							March 23, 2005

via facsimile and U.S. mail

Mr. Bobby Ray Adkins
Chief Executive Officer
b-Fast Corp.
660 Newtown-Yardley Road
Newtown, PA  18940

	Re:	b-Fast Corp.
		Form 10-KSB, Filed December 29, 2004
		Form 10-QSB, Filed February 11, 2005

		File No. 1-10190

Dear Mr. Adkins:

      We have reviewed the above filings and have the following
accounting comments.  Where indicated, we think you should revise
your documents in response to these comments.  If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

10-KSB for the year ended September 30, 2004

General

1. In future filings, it would be helpful if your document would
be
paginated and include a table of contents.

Management`s Discussion and Analysis or Plan of Operation

Comparison of the Years Ended September 30, 2004 and 2003

2. We note your disclosure that explains certain comparative
administrative cost changes.  Your disclosure indicates auditing
fees
decreased in 2004.  Please reconcile this disclosure for us to the
information you have included under Item 14.

Application of Critical Accounting Policies

3. We note your use of the equity method of accounting for your
investment in your 99% owned unconsolidated subsidiary.  We also
note
your expectation that FIN 46(R) is not expected to have a material
impact on your financial statements.  Please clarify to us why you
believe this to be your expectation.  In your response,
specifically
address the criteria outlined in paragraph 5 of FIN 46(R).

4. In addition, support your use of the equity method of
accounting
for this subsidiary on a supplemental basis, as it is our
understanding that 100% of the voting interest is held by Brant,
as
defined.  In your response, please address how maintaining the
checkbook, accumulating tax data and holding certain management
positions allows you to exercise significant influence.  Please
refer
to paragraph 17 of APB 18 for further guidance.

Controls and procedures

5. We note your conclusion regarding your evaluation of disclosure
controls and procedures as of a date within 90 days of the filing
date of the annual report.  Please note paragraph (b) of Rule 13a-
15,
as referenced in Item 307 of Regulation S-B, requires such
evaluation
be performed as of the end of each fiscal quarter.  In this
regard,
revise your disclosure to comply with the requirements of
Regulation
S-B, if such evaluation was performed.

6. You also state that there were no "significant changes" in your
"internal controls" and no factors that could "significantly
affect"
these controls subsequent to the date of their evaluation.
However,
Item 308(c) of Regulation S-B requires that you disclose any
change
in the registrant`s "internal control over financial reporting"
identified in connection with the evaluation required by paragraph
(d) of Exchange Act Rules 13a-15 or 15d-15 that occurred during
the
fourth fiscal quarter that has "materially affected, or is
reasonably
likely to materially affect, the small business issuer`s internal
control over financial reporting."  See also Regulation S-B,
paragraph 4(d) of Exhibit 31.  Revise your disclosure accordingly.

Note D - Summary of Significant Accounting Policies

	Revenue Recognition

7. Please expand your revenue recognition policy to address all
the
criteria of SAB Topic 13:A.1.  In addition, include a discussion
of
any significant arrangements that ultimately affect revenue
recognition.

	Restatement of Previously Issued Financial Statements

8. Please expand your disclosures to more clearly describe the
nature
of the error involved in your restatement.

Note E - Investment in Unconsolidated Subsidiary

9. Please provide all the required disclosures as described in
Section 310-b, Instruction 2(2)(iii) of Regulation S-B.

10. We note the asset described as "Note and Interest Receivable -
Member".  Please tell us why the Company and RTB/AS believes this
amount is collectable and how collectability is reasonably
assured.

Exhibits 31.3 and 31.4

11. Disclosure controls and procedures are now defined in Exchange
Act Rules 13a-15(e) and 15d-15(e).  See SEC Release No. 33-8238,
which became effective August 14, 2003.  Please revise your
certifications to conform to the format provided in Item
601(b)(31)
of Regulation S-B and refer to the appropriate locations for the
definitions.  Please also revise your disclosures under Item 8A to
include the appropriate references to the definitions of
disclosure
controls and procedures.

Form 10-QSB for the quarter ended December 31, 2004

Controls and procedures

12. We note your conclusion regarding your evaluation of
disclosure
controls and procedures.  However, your disclosure fails to state
when such evaluation was performed.  In this regard, revise your
disclosure to state when such evaluation was performed.  Please
note
paragraph (b) of Rule 13a-15, as referenced in Item 307 of
Regulation
S-B, requires such evaluation be performed as of the end of each
fiscal quarter.

13. You also state that there were no "significant changes" in
your
"internal controls" and no factors that could "significantly
affect"
these controls subsequent to the date of their evaluation.
However,
Item 308(c) of Regulation S-B requires that you disclose any
change
in the registrant`s "internal control over financial reporting"
identified in connection with the evaluation required by paragraph
(d) of Exchange Act Rules 13a-15 or 15d-15 that occurred during
the
fourth fiscal quarter that has "materially affected, or is
reasonably
likely to materially affect, the small business issuer`s internal
control over financial reporting."  See also Regulation S-B,
paragraph 4(d) of Exhibit 31.  Revise your disclosure accordingly.

Exhibits 31.5 and 31.6

14. Disclosure controls and procedures are now defined in Exchange
Act Rules 13a-15(e) and 15d-15(e).  See SEC Release No. 33-8238,
which became effective August 14, 2003.  Please revise your
certifications to conform to the format provided in Item
601(b)(31)
of Regulation S-B and refer to the appropriate locations for the
definitions.  Please also revise your disclosures under Item 3 to
include the appropriate references to the definitions of
disclosure
controls and procedures.

Closing Comments

      As appropriate, please amend your filings in response to
these
comments within 10 business days.  You may also wish to provide us
with marked copies of any amendment to expedite our review.
Please
furnish a cover letter with your amendment that keys your
responses
to our comments and provides any requested supplemental
information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      Direct questions regarding accounting issues and related
disclosures to Kevin Stertzel at (202) 824-5374, or in his
absence,
to Shannon Buskirk, at (202) 942-1826.  Direct questions relating
to
all other disclosure issues to the undersigned at (202) 942-1870.
Direct all correspondence to the following ZIP code:  20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director

??

??

??

??

b-Fast Corp.
March 23, 2005
page 5

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>