SecProbe.io

Division of Corporation
Finance UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

Mail Stop 4561
October 22, 2009
 Jason D. Davis President and Chief Executive Officer Blue Moose Media, Inc. 3113 St. Christopher Ct. Antioch, CA 94509
Re: Blue Moose Media, Inc.
  Amendment No. 1 to Registra tion Statement on Form 10-12G
Filed October 2, 2009
  File No. 000-53769

Dear Mr. Davis:

We have reviewed the above-referenced filing and the related response letter
dated October 1, 2009, and have the following comments.  If indicated, we think you
should revise your document in response to these comments.  After reviewing this information, we may raise additional comment s.  Unless otherwise noted, where prior
comments are referred to, they refer to our letter dated September 15, 2009.

Amendment No. 1 to Registration Statement on Form 10-12G

General
 1. We refer to page 4 of your response lette r.  Please be advised that the Tandy
representations must come directly fr om the company, not from your counsel on
behalf of the company.  Please provide thes e representations in a separate letter
from the company in tandem with your next  response, if the response is submitted
by your counsel.
 Item 1.  Business, page 2

 2. We note your revisions made in response to our prior comment 1 regarding the
sale of 20 million shares of your co mmon stock to Adam Krommenhoek.  Please
revise to discuss the material terms of  this transaction.  See Item 101(h) of
Regulation S-K.  In this regard, we re iterate our request that you file any

Jason D. Davis
Blue Moose Media, Inc.
October 22, 2009 Page 2
agreements relating to the ch ange of control as an exhibit.  See Item 601(b)(2) of
Regulation S-K.

Item 2.  Financial Information, page 5

3. We refer to your revisions made in respons e to our prior comment 5.  Specifically,
we note your disclosure that your general and administrative expenses for year end December 31, 2008 were $14,966.  Given your statement that you ceased your prior operations in 2007, it is unclea r how these expenses were incurred.
Please revise to include a detailed discussion of your operations for the last two completed fiscal years.  See Item 303(a)(3 ) of Regulation S-K and Instruction 1 to
Item 303(a).  In this regard, please re vise your business section to include a
description of your business during the fiscal year ended December 31, 2008.

Item 10.  Recent Sales of Unregistered Securities, page 9

4. We refer to our prior comment 11 and note that your “Holders” section on page 9
of your amended document continues to refe rence Section 3(b) of the Securities
Act and Rule 147 with regards to unregi stered sales of your securities, but you
have not provided the information required by Item 701 of Regulation S-K as it pertains to unregistered sales of your securities made pursuant to Rule 147.
Please provide the information require d by Item 701 of Regulation S-K as it
pertains to these unregistered sales, and be sure to include a description of the
facts relied upon to make this exemption available.  In addition, we remind you
that Section 3(b) of the Securities Act is an enabling provision  pursuant to which
the Commission has adopted exemptive rules.

* * * * *

Jason D. Davis
Blue Moose Media, Inc. October 22, 2009 Page 3
Please contact Ryan Houseal, Attorney-A dvisor, at (202) 551-3105 or, in his
absence, me at (202) 551-3735 with any questions.
     S i n c e r e l y ,          Barbara C. Jacobs      A s s i s t a n t  D i r e c t o r
  cc: Via Facsimile (435) 688-7318

 Cletha Walstrand, Esq.