SEC Company Response from BBMF CORP (CIK 0001095821) — May 27, 2005
BBMF CORP (CIK 0001095821)
Date: May 27, 2005 · CIK: 0001095821 · Accession: 0001145549-05-000944
AI Filing Summary & Sentiment
File numbers found in text: 000-27989
Referenced dates: April 25, 2005
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BBMF Corporation
Room 4302, 43rd Floor, China Resources Building
26 Harbour Road, Wan Chai, Hong Kong SAR
May 27, 2005
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: FORM 10-KSB FILED BY BBMF CORPORATION ("THE COMPANY") FOR THE YEAR ENDED
DECEMBER 31, 2004 AND FILED WITH THE COMMISSION MARCH 24, 2005, FILE NO.
000-27989
Ladies and Gentlemen:
Reference is hereby made to your letter dated April 25, 2005. The
following responses are keyed to the numbered paragraphs of your letter.
1. We present revenue recognized from revenue share and distribution
arrangements on a gross basis. Costs directly related to such revenue share and
distribution arrangements, such as commission and distribution expenses, are
recorded under "cost of sales". We believe this presentation is required by EITF
99-19, as the Company bears all risks and rewards of product ownership;
specifically, the Company: (a) acts as principal in such revenue share and
distribution arrangements; (b) maintains title to products at all times before
products are sold to ultimate end-users; (c) sets the price of all products
sold; (d) bears all inventory and credit risk in such transactions; and (e)
earns revenue from the sale of products.
2. We are advising the Commission that the intangible assets acquired from
Atlus were acquired pursuant to a Mobile Business Sales & License Agreement
dated September 27, 2004 (the "Agreement"), the terms of which expire 10 years
from September 27, 2004. Our right to use the assets acquired from Atlus will
expire with the Agreement and we have, therefore, determined it appropriate to
conclude that the acquired assets have a 10 year life.
In connection with our responses to your comments the Company acknowledges
that:
o the Company is responsible for the adequacy and accuracy of the disclosure
in the filings;
o 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 filings; and
o 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.
Yours sincerely,
Antony Ren Haw Ip
President
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