SecProbe.io

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Mail Stop 3-9									January 13,
2005

Nigel Johnson
Arch Management Services, Inc.
4-2341 West Broadway
Vancouver, BC V6K 2E6

Re:	Arch Management Services, Inc.
	Registration Statement on Form SB-2
      Filed December 17, 2004
	File Number 333-121356

 Dear Mr. Johnson:

      We have reviewed your filing and have 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
supplemental 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. Please provide us proofs of all graphic, visual or photographic
information you will provide in the printed prospectus prior to
its
use, for example in a preliminary prospectus.  Please note we may
have comments regarding this material.
2. In your amendments, please restate our comment.  Then explain
the
changes that have been made and reference the page numbers in
which
disclosure has been revised in response to a comment so that we
can
easily place your revised disclosure in its proper context.

Prospectus Summary, page 5
Overview, p. 1
3. Please explain what you mean by managing "business affairs" and
"promotion of business interests."  Also, please explain how the
Company will generate revenues from the services it provides.
Risk Factors, page 6
General
4. Please reorganize your Risk Factors grouping similar risk
factors
together with headings identifying the general nature of the risks
in
each subsection.  For example, risks relating to your company,
risks
relating to your industry and risks relating to an investment in
your
common stock.
Risks Relating to our Business, p. 5
5. Please include a separate risk factor disclosing that your
common
stock will be considered a penny stock.  The risk factor should
discuss the limitations on sales by broker dealers and the impact
on
liquidity.
"Our auditors have determined...," p. 6
6. Please explain the consequences not being able to continue as a
going concern to the investor so that investors can understand the
consequences.  Additionally disclose the consequences a going
concern
opinion may have on your ability to raise additional funds or
obtain
loans.
"We will not have sufficient funds...,"p.6
7. Please expand your discussion in this risk factor so that
investors can better understand the risk posed.  Specifically,
disclose the minimum amount you need to raise in order to begin
operations and the length of time you expect this amount to last.
Your discussion and heading should make it clear to potential
investors if this amount is not raised, it is likely that they
will
lose the entire amount of their investment.
8. Please revise to disclose that the offering expenses and the
loan
from Mr. Johnson will be paid first.  Therefore, if you raise less
than $26,813 investors will lose their entire investment.

"Investors in this offering may suffer substantial dilution...,"
p. 7
9. This risk factor appears to discuss two separate risks.  The
first
risk relates to potential dilution for investors in the offering.
The second risk relates to the ability to obtain additional
financing
when and if needed.  Please separate the risk factor into two
separate factors under distinct headings for each factor.
Alternatively, you may move the references to the need for
additional
funding into the subsequent risk factor, which also appears to
address the need for additional financing.

"Our operating results could be impaired if we become subject to
..."
p. 8
10. Since you are unaware of any current regulations, laws or
licensing requirements that exist or likely to be implemented, it
appears that this risk would apply to all companies in your
industry
as well as companies in all industries.  Please revise to tailor
the
risk to your business or eliminate it from your risk factor
discussion.

 "Our officers and directors currently own..." p. 9
11. In this risk factor, you should explicitly disclose the risk
that
shareholders will not be able to remove management from the
Company.
12. If Messrs. Johnson and Nutt are parties to any voting
agreements,
please disclose this information and file the agreement as an
exhibit
to the registration statement.

"You will be providing substantially all of the cash for our
operations ..." p. 10
13. According to footnote (12) on page 14, it appears that Mr.
Johnson will be repaid if you receive $26,813 in proceeds.
Therefore, it appears possible that investors may lose their
entire
investment and Messrs. Johnson and Nutt may only lose $400.
Please
revise to clarify.

"We have no employees...," p. 11
14. If Mr. Johnson or Mr. Nutt has any current plans to leave the
Company, please revise to disclose this information.

Description of Business, p. 21

15. Please revise to include a more detailed discussion of what is
involved in managing the business affairs of actors and
entertainers
and promoting their business interests.
16. Please disclose the primary attributes that lead to success in
your industry and describe how competitive the Company is with
respect to those attributes.  As one example only, if experience
representing actors and entertainers is an important indicia of
success in your industry, then you should disclose this fact and
then
describe how the Company`s experience compares to that of
competitors.  You should include similar analysis for all relevant
indicia in your industry.  To the extent that your experience or
skills compare unfavorably to the skills or experience of your
competitors, then provide a more detailed discussion of these
weaknesses in "Management consulting services provided to
individuals
working in the acting and entertainment industry ..." on page 8.
17. We note your discussion of Mr. Johnson`s appearance in
numerous
films and television programs.  However, we could not establish
his
appearance in the listed projects.  Please supplementally provide
us
with a description of his role in each of the listed projects.  We
may have further comment.
18. Please also disclose how Mr. Johnson`s experience in the
acting/entertainment industry provides a useful background in the
representation of entertainers in your industry.

19. We note your statement on page 24 that you would expect that
revenues may be generated within 90 days after the commencement of
your operations if your plans are successfully implemented.
Please
revise to clarify at what point you would consider your plans
successfully implemented.  For example, do you expect to begin
generating revenues 90 days after you acquire all necessary
equipment, your website is operational, and you begin
participating
in industry events or 90 days after you sign your first client?

20. Please revise page 25 to discuss the activities Mr. Johnson
has
engaged in to search for actors/entertainers who may agree to be
represented.
21. What sources is Mr. Johnson using to contact potential
clients.
For example, is he targeting acting schools, community theaters,
people he previously worked with etc.?
Executive Compensation, p. 28
22. Please disclose when you expect to begin paying compensation
to
your officers and directors and the initial amounts you expect to
pay.  If the figures currently included are the initial salary
amounts, please disclose this fact explicitly.

Financial Statements
Balance Sheet, page 30

23. Please confirm to us that deferred offering costs totaling
$20,000 have been incurred during the period from September 9,
2004
through November 30, 2004 and you reasonably expect the proceeds
of
the offering to exceed these costs. If these amounts have not been
incurred, please tell us how your accrual meets the conditions in
paragraph 8 of SFAS 5.  Expense costs of an offering if proceeds
are
not reasonably expected to exceed costs.

Statement of Operations, page 31

24. We note on page 28 that neither your officers nor directors
have
been paid any compensation.  Please revise your financial
statements
to recognize the fair value of uncompensated, contributed services
provided by these officers and directors or advise us.  See Staff
Accounting Bulletin Topic 1:B.1.for guidance.

Notes to Financial Statements
Note 1. Summary of Significant Accounting Policies
Revenue, page 34

25. Your disclosure that revenue is recognized on the sale and
delivery of a product or the completion of a service provided is
vague.  Please expand your disclosure to discuss the types of
management consulting service revenues you plan to provide and
disclose the related revenue recognition policy of each.  Please
address all of the criteria for revenue recognition listed in SAB
Topic 13:A.1. that must be met in your accounting policy.

Recent Accounting Pronouncements, page 35

26. Please disclose all recent accounting pronouncements that you
plan to adopt in the future, when you plan to adopt the accounting
pronouncement and what impact the adoption of the accounting
pronouncement will have on your financial statements.  Please
refer
to SAB Topic 11:M.

Note 3. Significant Transactions with Related Parties, page 35

27. Please confirm that the financial statements of Arch include
all
costs incurred by the officers and directors of its behalf.  We
note
that an officer has provided office services without charge.
Please
tell us the fair value of these services and explain to us why the
amounts are not material.

      As appropriate, please amend your filing in response to
these
comments.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested supplemental information.  Detailed cover letters
greatly facilitate our review.  Please file your cover letter on
EDGAR under the form type label CORRESP. Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert this action as 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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Please contact Zafar Hasan at (202) 942-7381or me at (202)
942-
1840 with any other questions.

      Sincerely,

      Jeffrey Riedler
      Assistant Director

cc:	Ken Finklestein
	2200-1420 Fifth Avenue
	Seattle, WA 98101
	206-374-8176
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