SecProbe.io

November 22, 2010

 Mark Cola  President Framewaves, Inc. 41B Bisbee Court, Unit B4 Santa Fe, New Mexico 87508
Re:  Framewaves, Inc.
Amendment No. 1 to Current Report on Form 8-K Filed November 12, 2010 File No. 033-02783-S

Dear Mr. Cola:
We have reviewed your amendment and comm ent response letter and have the following
comments.   In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments a pply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.

Item 2.01  Completion of Acquisition of Assets, page 3

Business, page 4

1. We note your response to comment five of our  letter dated October 14, 2010.  However,
your revised disclosure does not appear to address the potential affect of governmental
regulations on your operations.  In light of your current contracts with US Air Force
Material Research Laboratory and your assertion that ARMSTM technology is designed for
weapon’s application, we believe that a disc ussion of the application of government
regulations, particularly government contracti ng requirements, is appropriate.  If you do
not believe that government regulations are ma terial to your operations, please tell us
why in your response.

Mark Cola
Framewaves, Inc.
November 22, 2010
Page 2

Intellectual Property, page 8

2. We note that your utility applic ation 00139-50022, filed May 14, 2010, entitled,
“Controlled Weld Pool Volume  Control of Welding Processe s”, appears to cover both
your IPAQ technology and your Electronic Beam Direct Manufacturing control system.  Please provide additional disclosure e xplaining the differences between these
technologies.  This disclosure should also explain how this single patent covers both types of technology.  To the extent one tec hnology is an additiona l application of the
other, please clarify your disclosure.

3. We note your response to comment ten in our  letter dated October 14, 2010.  However,
we cannot locate where you have disclosed the term of your current patents.  Please direct
us to this disclosure or provide it in your amended Current Report on Form 8-K.
 Management’s Discussion and Analysis  or Plan of Operations, page 22

Results of Operations, page 24

4. Please further revise your Results of Operati ons disclosure to clea rly distinguish between
revenues recognized in the period presente d, revenues recognized after June 30, 2010,
and revenues you hope to generate in the future  based on existing contracts.  With respect
to future revenues based on existing contract s, provide information about the expected
timing of such revenues and a ny uncertainties surrounding your ability to generate these
revenues.  Disclose whether you will need to raise additional funds to finance the cost of
performing existing contracts.
5. Please clarify, if true, that you will not receive any additional revenues from the closed $749,728 US Air Force contract other than th e $18,414 already receiv ed and disclosed.

6. We note your response to comment 19 of our le tter dated October 14, 2010.  Please revise
to quantify the amount spent on each material item included in your general and administrative expenses for the period ended June 30, 2010.
 Certain Relationships and Re lated Transactions, page 34

7. We note your responses to comment 25 of our letter dated October 14, 2010.  Pursuant to
Item 404, with respect to each related party tr ansaction, you are required to disclose “the
basis on which the person is a related party.”  Please revise your disclosure to clarify,
with respect to the transactions on Februa ry 11, 2010 and February 23, 2010, the name of
the related person and the basis on which th e person is a related party.  Please see
Instruction 1 to Item 404(a) for a definition of “related person.”

Mark Cola
Framewaves, Inc.
November 22, 2010
Page 3

Recent Sales of Unregistered Securities, page 37

8. We note your response to comment 26 of our le tter dated October 14, 2010.  Pursuant to
Item 701(b), please provide names the persons or  class of persons to  whom the securities
were sold.

Exhibit 99.1
Audited Financial Statements for February 28, 2010
6. Subsequent Events
Asset Purchase Agreement, page 9
9. It is unclear to us how the text on pages 8 and 9 of Exhib it 99.1 addresses our concerns
communicated in comment 28 of our letter da ted October 14, 2010.  Please disclose and
explain to us how you accounted for the purchas e agreement with TMC for certain assets
of Beyond 6 Sigma, a division of TMC Corpora tion (“TMC”).   Describe the assets and
operations of Beyond 6 Sigma prior to the ac quisition.  Describe which portions of
Beyond 6 Sigma you acquired and what was retained by TMC. Describe for us your
consideration of whether the operations of Beyond 6 Sigma constituted a business; and whether historical and pro forma financia l statements for Beyond 6 Sigma are required
pursuant to Rules 8.04 and 8.05 of Regulation S-X.
10. We reiterate comment 29.  Tell us if you cons ider Beyond 6 Sigma to be the predecessor
company of B6 Sigma, Inc.  If not, pleas e explain why and iden tify and quantify the
assets and operations of the Beyond 6 Si gma division that were not acquired.
11. Similarly we reiterate comment 30.  We note you disclose that Beyond 6 Sigma was
formerly a division of TMC.  Explain to us, in  quantified detail, the nature and extent of
TMC’s operations, assets and liab ilities that were not  acquired as part of the purchase of
Beyond 6 Sigma.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Mark Cola
Framewaves, Inc.
November 22, 2010 Page 4

You may contact Joseph Kempf, accountant, at (202) 551-3352 or Robert Littlepage,
accountant branch chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters.  Please contact Brandon Hill, attorney-advisor, at (202) 551-3268, John Harrington, attorney-a dvisor, at (202) 551-3576 or me at (202) 551-3810 with
any other questions.
               Sincerely,
  /s/ Larry Spirgel
 Larry Spirgel
 Assistant Director