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Correspondence

 SearchMedia Holdings Limited

Floor 13, Central Modern Building

 468 Xinhui Road

 Shanghai, China 200060

March 13, 2012

 VIA EDGAR

 Larry Spirgel

 Assistant Director

 United States Securities and

Exchange Commission

 Division of Corporation
Finance

 Washington, D.C. 20549

Re:
SearchMedia Holdings Limited

 Form 20-F for the fiscal year ended December 31, 2010

 Filed
June 30, 2011

 Response dated January 26, 2012

File No. 333-158336

Dear Mr. Spirgel:

 We hereby respond to
the Staff’s comment letter, dated February 22, 2012, regarding the Company’s Form 20-F for the year ended December 31, 2010 (the “20-F”).

 For the Staff’s convenience, we have recited the Staff’s comments in boldface type and provided the response to each comment immediately thereafter.

Form 20-F for the fiscal year ended December 31, 2010

 Risk Factors, page 6

 Risk Related to Our Business and Operations, page 6

 Failures to obtain site owners’ consents or objections from site owners to the…, page 11

1.
 Please revise this risk factor to discuss in greater detail the magnitude of the current risk related to the challenge in assuring site managers
have obtained prior consent from site owners committees or site owners. Further, cite the PRC laws and regulations you reference and explain the material issues affecting your business

 Larry Spirgel

 Assistant Director

 March 13, 2012

  Page
 2

with same. We note that you “urge” site managers to obtain proper approvals. Please discuss what percentage of your sites has a display agreement in place with site managers and what
percentage of sites has received proper consent. Additionally, disclose whether any site owners have objected due to lack of consent terminating an agreement or resulting in the loss of a site. Lastly, discuss whether you are currently in the
process of resolving any issues involving proper consent.

 In response to the comment, in future filings we will revise this
risk factor substantially as follows.

 Article 7 of the Interpretation of the Supreme People’s Court on Several Issues Concerning
the Specific Application of Law in the Trial of Disputes over Partitioned Ownership of Building Areas” provides: “Any commercial use of public areas or facilities of residential properties shall belong to the scope of other
material matters stipulated in Article 76 -1-7 of Property Law.” Article 76-1-7 of Property Law provides: “other material matters concerning owners’ co-ownership and co-management rights shall be conducted
only with the prior consent of owners whose proprietary property area is over 50% of whole property area of the residential quarter and percentage is over 50%.” In accordance with these requirements, we take all reasonable efforts to
execute display agreements with site owners or owner committees before installing our media products. However, when we cannot locate all site owners or an owner committee has not been established, we execute display agreements with site managers. We
have obtained proper consents from site owners or owner committees for approximately 83% of our operations in terms of cost of sales and site manager consents for the remaining approximately 17% of our operations. Furthermore, in the past three
years, we have not had an agreement terminated or lost a site due to an objection for lack of consent, nor have we received any written objection from or been sued by any site owner or owner committee due to lack of consent.

2.
In a supplemental response, please provide us with an analysis as to the business arrangement and interests between all the parties to any given building mentioned
in this risk factor, aligned and conflicted interests and the business purposes behind the model, as opposed to making such arrangements with owners directly. We note your discussion on page 28.

In response to the comment, we respectfully advise the Staff that the different parties mentioned in the discussion each reflect the proper party from
whom we should seek to obtain consent before installing our media products. However, in some cases, as noted in our response to comment #1, if we cannot obtain the site owner’s consent, we will obtain the site manager’s consent.

 Unauthorized use of our intellectual property by third parties, and the expenses…, page 13

3.
 Please revise your disclosure under this risk factor heading to discuss in greater detail the landscape of intellectual property protection in
China. For example disclose that historically, the legal system and courts of the PRC have not protected

 Larry Spirgel

 Assistant Director

 March 13, 2012

  Page
 3

intellectual property rights to the same extent as the legal system and courts of the United States. Companies operating in the PRC continue to face an increased risk of intellectual property
infringement. Furthermore, you should disclose that the validity, application, enforceability and scope of protection of intellectual property rights for many internet-related activities, such as internet commercial methods patents, are uncertain
and still evolving in China and abroad, which may make it more difficult for you to protect your intellectual property, and could have a material adverse effect on your business, financial condition and results of operations.

 In response to the comment, in future filings, we will revise this risk factor substantially as follows.

We regard our trademarks, trade secrets and other intellectual property as critical to our success. Unauthorized use of the intellectual property used in
our business may adversely affect our business and reputation. We have historically relied on a combination of trademark law, trade secret protection and restrictions on disclosure to protect our intellectual property rights. We have entered into
confidentiality agreements with all our employees. We cannot assure you that these confidentiality agreements will not be breached, or that we will have adequate remedies for any breach.

 We are still in the process of registering in China the “SearchMedia” trademark and logo used in our business. We cannot assure you that our trademark application will ultimately proceed to
registration or will result in registration with a scope adequate for our business. Some of our pending applications or registration may be successfully challenged or invalidated by others. If our trademark application is not successful, we may have
to use different marks for affected services or technologies, or enter into arrangements with any third parties who may have prior registrations, applications or rights, which might not be available on commercially reasonable terms, if at all.

 The validity, enforceability, and scope of protection available under intellectual property laws with respect to trademark and trade secrets
in China are uncertain and still evolving. Implementation and enforcement of PRC intellectual property-related laws have historically been deficient and ineffective. Accordingly, protection of intellectual property rights in China may not be as
effective as in the United States or other western countries. One example of a protective measure regarding intellectual property, pre-litigation injunction relief, is still evolving in China and this protective measure needs more detailed guidance
on implementation. Furthermore, policing unauthorized use of proprietary technology is difficult and expensive, and we may need to resort to litigation to enforce or defend our intellectual property or to determine the enforceability, scope and
validity of our proprietary rights or those of others. Any such litigation or an adverse determination in any such litigation, could result in significant costs to the Company and a diversion of resources and management attention.

 Larry Spirgel

 Assistant Director

 March 13, 2012

  Page
 4

 We rely on computer software and hardware systems in managing our operations…,
page 13

4.
In future filings, please address in greater detail the risks associated with your computer hardware and software system including whether there has been any
material occurrence and what consideration you have given to the need to discuss a specific incident or incidents, any known and potential costs or other consequences, and impact on MD&A. Refer to CF Disclosure Guidance: Topic No. 2,
Cybersecurity dated October 13, 2011 for further guidance.

 In response to the comment, in future filings we will
revise this risk factor substantially as follows.

 We rely on the proper operation and maintenance of our computer system. Any
malfunction, capacity constraint or operation interruption for any extended period may have an adverse impact on our business.

 The
satisfactory performance, stability, and security of our computer system and our network infrastructure are critical to our reputation and our ability to attract and retain advertisers. Our information system provides a database of information
regarding advertising records and various other facets of the business to assist management and to help ensure effective communication among various departments and offices of our company. Accordingly, any failure to maintain the satisfactory
performance, stability, security and availability of our computer system may cause significant harm to our reputation and to our advertisers’ interest in advertising their products. Any server interruptions, break-downs or system failures,
including failures which may be attributable to events within or outside our control, could reduce the attractiveness and availability of our product offerings. Our computer systems are also susceptible to damage from computer viruses, fires,
floods, earthquakes, power losses, telecommunication failures, computer hacking, and similar events. We do not maintain insurance policies covering losses relating to our network systems or other assets. As a result, any capacity constraints or
operation interruptions for any extended period may have a materially adverse impact on our revenues and results of operations.

 Risks
Relating to Doing business in the People’s Republic of China, page 14

 If the PRC government determines that the contractual
arrangements that establish…, page 14

5.
Please revise this risk factor to disclose the following:

•

 Discuss in greater detail the transactions between Jingli Shanghai Advertising Co., Ltd. and Ad-Icon Advertising (Shanghai) Co., Ltd. Specifically,
you state that in 2010 Ad-Icon Shanghai acquired “some” of Jingli Shanghai’s subsidiaries.

 Larry Spirgel

 Assistant Director

 March 13, 2012

  Page
 5

 Be specific as to the nature of your “acquisition,” stating equity
ownership or contractual arrangement without equity ownership where appropriate.

 Please revise to state the specific
and full names of these entities and describe their current status within your corporate structure. Revise your Organizational Structure chart on page 36 accordingly.

 In response to the comment, we will, where appropriate, replace the word “acquisition” with the phrase “transfer of equity interests,” or a similar phrase, which better describes the
nature of the transactions disclosed in this risk factor. Also, in future filings, to the extent the risk factor remains applicable, we will revise the risk factor substantially as follows in the discussions below and revise the organizational
structure chart as it appears in Annex A to this letter.

 In 2010, as part of our steps to exert direct equity ownership over our
acquired businesses, our contractually controlled VIE, Jingli Shanghai, transferred 100% of the equity interests in Shanghai Botang Advertising Co., Ltd., Shanghai Haiya Advertising Co., Ltd., Beijing Wanshuizhiyuan Advertising Co., Ltd., Wuxi
Ruizhong Advertising Co., Ltd., and Shenyang Jingli Advertising Co., Ltd. to our indirect wholly-owned subsidiary Ad-Icon Shanghai.

•

 Revise to discuss the current status and history of Shanghai Sige Advertising and Media Co., Ltd., Shenzhen Dale Advertising Co., Ltd. and Beijing
Conghui Advertising Co., Ltd. We note that these entities are not reflected on your Organizational Chart found on page 36 and with the exception of Shanghai Sige Advertising and Media Co., Ltd. are not discussed elsewhere in your Form 20-F.

 Shanghai Sige Advertising and Media Co.,Ltd., Shenzhen Dale Advertising Co., Ltd., and Beijing Conghui Advertising Co.,
Ltd. were predecessors of Jingli Shanghai before the Company’s restructuring in 2007. In connection with this 2007 restructuring, these entities were merged into Jingli Shanghai and have been inactive since that time. This restructuring was not
relevant in 2010. In future filings, we will delete the discussion of these companies in this risk factor.

•

 You state in the final sentence that you have entered into agreements with Jingli Shanghai and each of the shareholders of Jingli Shanghai to gain
control over this entity. Please revise to discuss the specific agreements in place and the effect and purpose of each agreement. File these agreements as exhibits.

 In response to the comment, we respectfully refer the Staff to page 38 of the Form 20-F “Contractual Arrangements with Jingli Shanghai and its Shareholders.” Those agreements were
previously filed with the SEC.

 Larry Spirgel

 Assistant Director

 March 13, 2012

  Page
 6

 Specifically, the English translations of (A) the Exclusive Technology Consulting and Service
Agreement between Jieli Consulting and Jingli Shanghai, dated as of September 10, 2007 was filed as Exhibit 10.6 to the Company’s Current Report on Form 8-K filed on November 5, 2009 and incorporated by reference therein as Exhibit
10.6 to ID Arizona Corp.’s Registration Statement on Form S-4, (B) the Exclusive Call Option Agreement among Jingli Shanghai, its shareholders and Jieli Consulting, dated as of September 10, 2007 was filed as Exhibit 10.7 to the
Company’s Current Report on Form 8-K filed on November 5, 2009 and incorporated by reference therein as Exhibit 10.7 to ID Arizona Corp.’s Registration Statement on Form S-4, (C) the Equity Pledge Agreement among Jingli Shanghai,
its shareholders and Jieli Consulting, dated as of September 10, 2007 was filed as Exhibit 10.8 to the Company’s Current Report on Form 8-K filed on November 5, 2009 and incorporated by reference therein as Exhibit 10.8 to ID Arizona
Corp.’s Registration Statement on Form S-4, (D) the Power of Attorney by the shareholders of Jieli Consulting dated as of September 10, 2007 was filed as Exhibit 10.9 to the Company’s Current Report on Form 8-K filed on
November 5, 2009 and incorporated by reference therein as Exhibit 10.9 to ID Arizona Corp.’s Registration Statement on Form S-4, and (E) the Loan Agreement between the shareholders of Jingli Shanghai and Jieli Consulting, dated as of
September 10, 2007 was filed as Exhibit 10.10 to the Company’s Current Report on Form 8-K filed on November 5, 2009 and incorporated by reference therein as Exhibit 10.10 to ID Arizona Corp.’s Registration Statement on Form S-4.

•

 We note your statement that you may “not be able to renew these contracts with Jingli Shanghai and/or its shareholders.” Please disclose
the kick-out rights of these agreements, meaning who has the right to renew or not on which dates.

 In response to the
comment, we respectfully advise the Staff that in accordance with the provisions of the VIE agreements, the agreements will be renewed automatically for 10 years after the expiration of the initial 10-year term, unless we notify Jingli Shanghai
and/or its shareholders in writing three months in advance that we will not renew the agreements.

 Supplementally, we respectfully advise the
Staff that because the VIE structure was terminated in accordance with our rights under our contractual arrangements with Jingli Shanghai as of December 23, 2011, these agreements are no longer material to our continuing operations.

•

 Disclose whet