SecProbe.io

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Mail Stop 3561

            September 15, 2005

Hugo M. Cancio, Chief Executive Officer
Fuego Entertainment, Inc.
19250 NW 89th Court
Miami, Florida  33018

      Re:	Fuego Entertainment, Inc.
      Registration Statement on Form SB-2
      Filed August 17, 2005
      Amendment No. 1 to Registration Statement on
      Form SB-2
      Filed August 19, 2005
      File No. 333-127612

Dear Mr. Cancio:

      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
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

General
1. In preparing your responses to these comments, please consider
that evaluations of materiality should not be based solely on
quantitative factors, but should also include consideration of
qualitative factors that a reasonable investor would deem
important
in making an investment decision, including the potential impact
of
corporate activities upon a company`s reputation and share value.
In
this regard, we note that legislation requiring divestment from,
or
reporting of interests in, companies that do business with US-
designated state sponsors of terrorism has been adopted by Arizona
and Louisiana.
2. Please provide the information about your shares` dilution as
required by Item 506 of Regulation S-B.

Front Cover Page of Prospectus, page 3
3. You state that there is no trading market for your securities.
Also, you state that your share price will be $0.25 "until the
shares
are listed on the OTC Bulletin Board or other national exchange,
and
thereafter at prevailing market prices or privately negotiated
prices."  Please state, here and in the summary, that you cannot
guarantee that you will be quoted on the Over-the-Counter Bulletin
Board or other national exchange and discuss how this affects the
liquidity of your common stock.
4. Please remove the August 15, 2005 date from your cover page and
insert a blank space.  The date of the prospectus should reflect
the
effective date of the registration statement.

Number of Shares Outstanding, page 7
5. Please disclose throughout the document the number of
outstanding
shares as of the most recent practicable date.

Risk Factors, page 8
6. Your Risk Factors section should be a discussion of the most
significant factors that make your offering speculative or risky.
You should not present risks that are generic or contain
boilerplate
language that could apply to any issuer or any offering.  Please
revise your Risk Factors section to describe the risks specific to
you and your business.  See Item 503(c) of Regulation S-B.  As
examples, please consider the following risk factors:

* "We may require additional funding in the future."

* "We may suffer infringement of our copyrighted materials."

* "We may be unable to retain key employees or consultants or
recruit
additional qualified personnel."
We may have additional comments based upon your revisions.
7. Please include a risk factor that discloses the illiquidity of
your common stock.
8. Please describe any dependence on third parties.
9. Please discuss Mr. Cancio`s significant stock ownership and
control.

The entertainment industry is highly competitive and there is no
assurance..., page 9
10. You state that you compete with "other major, mini-major and
independent recording companies."  Please disclose your size in
relation to other recording companies.

We may be unable to retain key employees or consultants or recruit
additional..., page 10
11. Please identify any key consultants on whom you rely, or
revise
the risk factor heading.

Management`s Discussion and Analysis or Plan of Operation, page 12
12. Please expand this section to discuss known material risks,
trends, and uncertainties that will have or are reasonably likely
to
have a material impact on your revenues, operations, liquidity, or
income over the short and long terms, and the actions you are
taking
to address them.  Additionally, please discuss your ability to
secure
sources of supply and customers, generate revenues, raise
additional
financing, and manage other significant risks and uncertainties
that
are material to your plan of operations and business.  See SEC
Release No. 33-8350 and Item 303 of Regulation S-B.

Plan of Operation, page 13
13. Please revise your plan of operation discussion to include an
overview of how have generated revenues since inception and how
you
plan to generate revenues in the next 12 months.  Please also
disclose significant costs and expenses incurred thus far and that
you expect to incur in the next 12 months.  Describe your current
significant customers or projects and how you intend to grow your
business in the next 12 months.  Please disclose the required
amount
you will need to continue operations for the next 12 months, how
you
will raise the required financing, and the impact on your business
if
you fail to raise the required amount.

Filmed Entertainment, page 13
14. You state that you are producing three documentaries and
developing a reality show.  You describe the reality show on pages
17
and 18, but you do not discuss the documentaries in the same
detail.
Please describe each of the documentaries and their stages of
development.
15. Please provide examples of the existing project opportunities
of
which you are "actively seeking...to negotiate the licensing or
purchase."
16. You state that you utilize your "extensive network of
contacts"
to access quality products by "established industry participants."
Please clarify your meaning of "extensive network of contacts" and
"established industry participants" so that your readers will have
an
idea of the access these contacts will provide you and the quality
of
the available products.  Please describe any specific marketing
efforts and their costs.

Music Entertainment, page 13
17. You state that you intend to license the music library
catalogue
of Ciocan Entertainment Music Group, L.L.C. to target non-Hispanic
markets that Ciocan Entertainment Music Group, L.L.C. has yet to
access.  Please describe the terms of any licensing agreements or
arrangements you have with Ciocan Entertainment and Music Group,
L.L.C.  If you have no agreements, please disclose this fact and
discuss the likelihood and basis for stating that Ciocan
Entertainment and Music Group, L.L.C. will allow you to license
its
music library.  If you have an agreement, it appears that it is a
material contract you should include as an exhibit.

Also, please describe Ciocan Entertainment and Music Group,
L.L.C.`s
business operations and any other information relevant information
for your readers to understand the impact licensing Ciocan
Entertainment Music Group, L.L.C.`s music library will have on
your
business operations.

Other Services, page 13
18. You state that you will act as an agent and contract
organization
for certain entertainment projects that are fully developed by
third
party producers and you describe the services that you may
provide.
Please describe your specific duties and responsibilities in
performing these services.  Further, please identify the
entertainment projects and third party producers to which you
refer.

19. You state that you do not expect to increase significantly
your
number of employees.  Please state whether you expect to hire any
employees and if so, disclose the number you intend to hire.
20. Please disclose the services that you will attempt to
outsource.

For the Period from December 30, 2004 (Inception) to May 31, 2005,
page 14
21. You state that in your first five months of operation, you had
a
net income of $39,489 and you had gross revenues of $121,628 for
filming and $3,500 for publicist services.  Please provide a
detailed
description of the filming in which you engaged and the publicist
services you provided.  Please revise your disclosure to explain
the
nature of this filming project which generated substantially all
of
your revenue in the five months ended May 31, 2005, the expected
term
of the revenue arrangement, and if you reasonably expect the
filming
project to have a favorable or unfavorable impact on revenues and
operating income in the near term.

Liquidity and Capital Resources, page 14
22. In light of your current working capital deficiency, your
statement that working capital and anticipated cash flows are
adequate to continue operations is insufficient in disclosing
known
trends or uncertainties related to your cash flows, capital
resources, or liquidity.  Please quantitatively identify how you
expect to meet your short and long-term cash requirements and
maintain operations.  Please disclose your reliance on issuing
common
shares as a form of liquidity, the probability this financing
method
will continue to be available to you in the future, and the
potential
dilutive effects of issuing additional shares.  Please revise
throughout your document accordingly.  See Item 303 of Regulation
S-B
and Section IV of SEC Release No. 33-8350.

Description of Business, page 16
23. Under your Distribution subsection on page 13, you disclose
that
you have established an internal distribution network for your
products while your disclosure contained within this section
states
you outsource the distribution process.  Please reconcile these
disclosures and discuss the following:

* state what portion of your distribution process is internal
and/or
external;

* state which products are distributed internally and/or
externally;

* discuss the terms of any significant distribution agreements and
the impact on your business if you lose or terminate any of these
agreements.

Current Business Operations, page 16
24. We note your disclosure in this subsection that you "were
founded
by [your] President, Hugo Cancio, who has spent the last five
years
successfully owning and operating Ciocan Entertainment & Music
Group,
a record label and film production company that produces Cuban and
world entertainment."  We also note that Hugo Cancio`s company,
Ciocan Entertainment, conducts some of your operations through
licensing and other arrangements.  To the best of your knowledge,
please describe any previous, current, or planned contacts that
Ciocan Entertainment has with Cuba, including as a result of
production and talent-searching efforts, sales, communications,
banking, or financial transactions, and other business
arrangements.
25. Please advise or revise the discussions of your current
business
operations, distribution and publishing, product descriptions, and
service descriptions to make a distinction between the current
products and services currently contributing to operating income
of
Fuego Entertainment, Inc. from the products and services
anticipated
to have an effect on future operating results.  To the extent a
licensing or other contractual arrangement with Ciocan
Entertainment
and Music Group L.L.C. has or will contribute to the results of
operations of the company, please discuss these significant
agreements to the extent they are material.
26. Please disclose any patents, trademarks, licenses, franchises,
concessions, royalty agreements, or labor contracts you may have,
if
any, and their duration.  See Item 101(b)(7) of Regulation S-B.
If
none, please remove the first full risk factor on page 9.

Distribution and Publishing, page 16
27. You state that you out-source your distribution process to
over
100 distributors.  Please describe this out-sourcing process, the
methods you use to select these distributors, the products that
your
largest clients distribute, and the amount of your products your
largest clients distribute.  See Item 101(b)(2) of Regulation S-B.
28. Please describe the products you license from Sun Flower
Products, and describe the terms of the agreement.

Product Descriptions, page 16
29. Your document is very sparse in details about your products
and
services.  Please thoroughly revise this subsection, and other
appropriate sections in your document, to describe in much greater
detail your entertainment products.  See Item 101(b)(1) of
Regulation
S-B.  Specifically, you state that you produce and distribute
films,
music, videos, documentaries, and other related entertainment
products.  For the five categories you list, please disclose the
products that you produce and distribute, the manner in which you
produce and distribute the products, the amount of each product
you
produce and distribute, and any other material information.  We
may
have further comments when we read your response.

Service Descriptions, page 17
30. Please disclose which artists you manage and represent.  In
this
regard, please disclose whether you manage or represent Vocal
Sampling, the US Tour of Havana Night Club`s Celebrate Freedom
Tour
`05, and Anthony Pullicino.  If not, please clarify your
relationship
to these individuals and events.  We may have further comments
when
we read your responses.
31. Please identify the freelance individuals and marketing firms
that assist you with your advertising and promotional functions.
Please describe the specific services that they provide.
32. You state that you are investigating the possibility of
bringing
your advertising and promotional services "in-house in the near
future as revenues permit."  In this subsection, your Advertising
and
Marketing Strategy on page 21, and all other appropriate places in
your document, please discuss your plans and timeline for bringing
these services in-house, if your revenues would permit it, and how
this change would affect your business operations.  Please
disclose
the revenues you are required to generate that would allow you to
accomplish this change.

Notable Artists and Projects, page 17
33. It appears from your disclosure in this subsection that Vocal
Sampling, which "is a Cuban six-man a cappella group," is one of
your
clients.  We also note that you are co-producing "U.S. Tour of
Havana
Night Club, Celebrate Freedom Tour 05."  With a view to
disclosure,
please describe for us the nature of your relationships with Vocal
Sampling and the US Tour of Havana Night Club, including any
direct
and indirect contacts with Cuban nationals or entities associated
with both entertainment groups.  Your response should clearly
describe the extent of your contacts with Cuba resulting from
these
relationships.  For example, advise us whether any of your
representatives travel on business to Cuba or transact business
with
banks or other entities in Cuba.  Please address the materiality
of
any such contacts or arrangements, and your view as to whether
those
operations or arrangements constitute a material investment risk
for
your security holders, in light of the fact that Cuba is subject
to
economic sanctions administered by the Treasury Department`s
Office
of Foreign Assets Control and identified as a state sponsor of
terrorism by the U.S. State Department.  Please note that by
including more relevant details in your response you facilitate
the
review and disclosure process.
34. Also, please describe for us the extent of your current and
planned operations in, or contacts with, Cuba due to operations or
relationships other than with Vocal Sampling and the US Tour of
Havana Nig