SecProbe.io

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Mail Stop 0407

      January 25, 2005

Gary Labrozzi
President
Brandmakers, Inc.
2901 Florida Avenue, Suite 806
Coconut Grove, Florida  33133

	RE:  	Brandmakers, Inc.
      Preliminary Schedule 14C
      Filed on December 23, 2004
      File No. 0-28184

Dear Mr. Labrozzi:

	We have limited our review of your information statement to
consideration of your disclosure concerning your delinquency in
periodic reporting and related matters, and we have the following
comments.  Please revise your information statement to comply with
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.
1. Please revise your information statement to prominently
disclose
that you have not filed your 2003 fiscal year Form 10-K and
subsequent periodic reports, as you have been obligated to do
under
the Securities Exchange Act of 1934.  Also, explain why you have
failed to file the reports.

2. Please discuss why you have agreed to issue post-split common
stock to your former officers and directors, and indicate the
aggregate percentage of outstanding post-split common stock the
former officers and directors will be issued.  We may have further
comment upon review of your response.

*	*	*	*

	Please file a revised preliminary information statement in
response to these comments.  You may wish to provide us with
marked
copies of any revision to expedite our review.  Please furnish a
cover letter with your revised preliminary information statement
that
keys your responses to our comments and provides any requested
supplemental information. Detailed cover letters greatly
facilitate
our review.  Please file your cover letter on EDGAR.  Please
understand that we may have additional comments after reviewing
your
filing and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* 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 laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

	Please contact Cheryl Grant, Staff Attorney, at (202) 942-
1916,
or me, at (202) 942-1797, with any questions.

					Sincerely,

					Michele Anderson
					Legal Branch Chief

cc:	Joel Bernstein, Esq.
	786-513-8522 (fax)

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Mr. Labrozzi
Brandmakers, Inc.
January 25, 2005
Page 3

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