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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

Date
May 27, 2005
Author
President
Form
CORRESP
Company
BBMF CORP (CIK 0001095821)

Letter

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

<PAGE>

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

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

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
<PAGE>

                                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
</TEXT>
</DOCUMENT>