SecProbe.io

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                            THE O'NEAL LAW FIRM, P.C.
                            17100 East Shea Boulevard
                                   Suite 400-D
                          Fountain Hills, Arizona 85268
                              (480) 812-5058 (Tel)
                              (480) 816-9241 (Fax)

                                November 15, 2005

H. Christopher Owings Securities and Exchange  Commission 450 Fifth Street, N.W.
Washington, D.C. 20549

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

Dear Mr. Owings:

Pursuant to your conversation with Ivan Braverman, the company's auditor, we are
requesting your expedited response to Mr. Braverman's response to comment 32 set
forth below of your comment letter dated October 27, 2005 in connection with the
above-referenced filing. Once we have your response to this comment, we will
proceed to file a 4th Amendment to Fuego Entertainment's SB-2 along with our
complete response letter.

     32.  Additional  disclosures  have  been  added  to Note  1-Investment,  to
     incorporate  the  requested  information  and as per  paragraph  10 of SFAS
     No.50,  and we have  also  added  additional  information  below  for  your
     understanding  of the  investment  which  will  not been  disclosed  in the
     footnote.  Please respond as the  completeness  of the  information we have
     provided.

     Footnote disclosure:

INVESTMENT

     The  Company  invested  a total  of  $57,400  in a  series  of  shows to be
presented  in 5 cities in the United  States,  from which it was to receive  the
return of its  investment  based on a percentage  of ticket sales from all shows
performed,  and then  participate  in the net  income of all of the shows  after
their completion which is anticipated to occur at the end of the summer of 2006.

     The three shows performed as of May 31, 2005,  exhausted the budgeted funds
available by the producer/promoter since the promoter/promoter  decided to incur
additional  costs  for high  definition  filming,  production  costs  for a live
recording of a compact disc, and a substantial payment to secure the services of
an Oscar  Winner  Film  Director.  In the  opinion of the  president/CEO,  whose
background includes  substantial tour production,  the majority of shows on tour
typically incur  front-end costs of this type and magnitude,  prior to realizing
the financial benefits from subsequent shows during the tour.

     As a result of these increased show costs,  the initial  royalty  agreement
with the Company was  renegotiated  to allow deferral of the initial  payment to
the Company of its investment until the December 31, 2005 show is performed. The
Company  does not  consider  this  deferral as a basis for  amortization  of its
investment or impairment thereof,

     In addition to expecting  full recovery of the investment in December 2005,
the Company believes  additional shows may be added to the tour depending on the
success achieved during the remaining shows.

     The tour being presented is a more expanded  version of the same show being
presented  semi-weekly  at the Stardust  hotel in Las Vegas,  Nevada,  which has
enjoyed near sell-out performances.

     Information not disclosed in the footnote:

(from Mr.Cancio)

As  part  of  the  6  city   Celebration   tour  of  Havana   Night  Club,   the
producer/promoter was supposed to present only one show in Miami, however, after
the  original  show sold out  within a week after  tickets  went on sale and six
weeks  prior to the day of the show,  the  producer/promoter  decided to add two
additional  shows  in  Miami  in order  to  provide  for the  filming  of a high
definition  DVD, the hiring of an Oscar winning  director and the recording of a
CD/Sound Track. These three shows combined,  used up all funds available for the
tour.

Understanding  the business as I do, having  produced many of them, I understood
that being able to release a high  definition  DVD  directed  by a renown  Oscar
winning  director and releasing a live album prior to a tour would  dramatically
impact  future  ticket  sales for the  remaining  shows of the tour. I therefore
decided  to allow the shows'  producer/promoter  to defer the  repayment  of the
Company's original investment for the next 5 shows to take place.  However, this
was agreed with the  understanding  that I/fuego  participate  in any additional
shows added to the next 5 pending shows as the result of a sold out event in any
of the cities, which, if it happens, it will automatically trigger an additional
show.

An example of this is the next show which is scheduled  for December 31s. at the
Miami  Arena,  a 15,000  seat  venue.  This will be the fourth  time the show is
presented in the same city as the result of its popularity. It is my belief that
this show alone will allow total recovery of our original  investment,  and then
some.

Please do not hesitate to contact us if you have any further questions.

Very truly yours,

/s/William D. O'Neal
-------------------------
William D. O'Neal
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