SecProbe.io

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Mail Stop 0407

      May 2, 2005

Gary Labrozzi
President
Brandmakers, Inc.
721 Crandon Blvd.
Suite 308
Key Biscayne, Florida  33149

	RE:  	Brandmakers, Inc.
      Preliminary Schedule 14C
      Filed on April 21, 2005
      File No. 0-28184

Dear Mr. Labrozzi:

	As we indicated in our prior letter, 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.

1. Please disclose in your information statement that, on April
27,
2005, the Commission initiated public administrative proceedings
to
revoke the registration of your common stock due to your failure
to
file the required periodic reports and that, following a future
hearing, an administrative law judge will determine whether to
revoke
the registration or, alternatively, to suspend the registration
for a
period not exceeding twelve months.

2. In addition, disclose that the Commission announced the
temporary
suspension of trading in your common stock (trading symbol BMKS)
beginning at 9:30 a.m. EDT on April 27, 2005, and terminating at
11:59 p.m. EDT on May 10, 2005.

3. To the extent that the revocation proceeding and trading
suspension affect the plans or actions you have outlined in the
information statement--concerning stock purchase agreements,
creditor
arrangements or otherwise, please revise your disclosure to
reflect
the effect.

4. Please file your revised preliminary Schedule 14C that is
responsive to our comments on EDGAR using the submission tag
"PRER14C" for preliminary revised materials, and not "PRE14C."

*	*	*	*

	Where appropriate, please revise your filing 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.

	Please contact Cheryl Grant, Staff Attorney, at (202) 551-
3359,
or me, at (202) 551-3833, with any questions.

					Sincerely,

					Michele Anderson
					Legal Branch Chief
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Mr. Labrozzi
Brandmakers, Inc.
May 2, 2005
Page 2

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