SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>cmesecresp120704v2.txt
<DESCRIPTION>CME CORRESP 120704
<TEXT>
                                 CORRESPONDENCE

                          CYBER MERCHANTS EXCHANGE INC.
                          4349 Baldwin Avenue, Suite A
                               El Monte, CA 91731

December 7, 2004

Patrick Gilmore
Securities and Exchange Commission
Washington D.C. 20549

RE: Item 4 Form 8-K filed October 25, 2004

Dear Mr. Gilmore:

Pursuant to your letter dated November 5, 2004 and received December 6, 2004,
this is to confirm the following:

The Company (Cyber Merchants Exchange, Inc.) is responsible for the adequacy and
accuracy of the disclosure in the filings;

Commission staff comments or changes to disclosure in response to staff comments
in the filings reviewed by the staff 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.

The Company is filing a Form 8-K/A in response to your letter.

Please let me know if you have any further comments.

                                                  Very truly yours
                                                  Cyber Merchants Exchange, Inc.
                                                  /s/ Frank S. Yuan
                                                  President

</TEXT>
</DOCUMENT>