SecProbe.io

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							July 6, 2005

Mail Stop 4561

B. Alva Schoomer
Chief Executive Officer and Chairman
BAS Consulting, Inc.
5675B Baldwin Court
Norcross, GA	30071

      Re:	BAS Consulting, Inc.
			Schedule 14C Information Statement
			Filed June 20, 2005
			File No. 0-50212

Dear Mr. Schoomer:

      This is to advise you that we have limited our review of the
above registration statement to the following comments.  Where
indicated, we think you should revise your document in response to
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 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.

General
1. We note that on June 15, 2005 you filed a Form 8-K disclosing
the
terms of the Share Exchange Agreement entered into between you and
Earjoy Group Limited relating to a merger between the two
companies.
The Share Exchange Agreement identifies several conditions
precedent
to the closing in Article X, which include, among others, an
amendment to your Articles of Incorporation increasing the number
of
authorized common shares available for issuance and a 1 for
6.433138
reverse stock split of your common stock We also note that the
purpose of your Schedule 14C is to inform your shareholders that
you
have obtained written consent from the majority of the
stockholders
approving: (1) an amendment to your articles of incorporation to
increase the number of authorized common shares from 24,000,000 to
75,000,000; (2) a reverse stock split of the Company`s stock; and
(3)
the execution of the Share Exchange Agreement.  It appears that
your
Information Statement must include the information required by
Item
13 and 14 of Schedule 14A since the increase in the amount of
authorized common stock and the reverse stock split are a
conditions
to the Share Exchange Agreement.  Therefore, please amend your
Information Statement to include the disclosure required by Item
13
and 14 of Schedule 14A or tell us why you believe you are not
required to do so.  See Note A to Schedule 14A and Item 1 to
Schedule
14C.

Furnishing Information, page 3
2. It appears that the information incorporated by reference will
not
be simultaneously delivered to shareholders with the Information
Statement.  Please tell us why the incorporated information is not
being delivered with the Schedule 14C and/or why you have not
otherwise included an undertaking to provide copies of the
information without charge.  Refer to Notes D.2, D.3 and D.4

Exchange of Stock Certificates and Payment for Fractional Shares,
page 9
3. Please expand your disclosure to include a detailed description
of
the formula you will use to calculate the cash payment for
fractional
shares held after the reverse split.

      As appropriate, please revise your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the revisions to expedite our review.  Please furnish a cover
letter
with your revised document that keys your responses to our
comments
and provides any requested information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your revised document 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 our review of your filing or in
response to our comments on your filing.

	Please direct any questions to Charito A. Mittelman at (202)
551-3402, or the undersigned at (202) 551-3694.

Sincerely,

Owen Pinkerton
Senior Counsel

cc: 	Gary Wolff, Esq.  (via facsimile)

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B. Alva Schoomer
BAS Consulting, Inc.
July 6, 2005
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