SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -3561

         September  7, 2010

Andreas Wilcken, Jr.
President
Moving Box Inc.
222 E . Jones Ave.
Wake Forest , NC 27587

Re: Moving Box Inc.
 Registra tion Statement on Form S-1
Filed August 11, 2010
File No. 333-168738

Dear Mr. Wilcken :

We have reviewed your registration statement and have the following comments.
In some of our comments, we may ask you to provide us with information so we may
better u nderstand your disclosure.

Please respond to this letter by amending your registration statement and
providing the requested information. If you do not believe our comments apply to your
facts and circumstances or do not believe an amendment is appropriat e, please tell us why
in your response.

After reviewing any amendment to your registration statement and the
information you provide in response to these comments, we may have additional
comments.

General

1. We note  that the selling shareholders acquired  these shares very recently, and for
the same price being offered.  If the selling shareholder s acquired the securities
with a view toward distribution please revise to name the selling shareholders as
underwriters .  Alternatively, please provide us your a nalysis as to how these
shares were not acquired with a view to distribution.

2. Please advise us why you believe these selling shareholders are not affiliates
seeking to sell their shares in an offering by or on behalf of the issuer for purposes
of Rule 41 5(a)(4) of Regulation C under the Securities Act.  We may have further
comment.

Andreas Wilcken, Jr.
Moving Box Inc.
September 7, 2010
Page 2

3. Please revise the disclosure at each relevant place in the filing to provide the basis
for setting the share price in this offering at $0.0 2.  Your explanation should
address the fact, as appropriate, that the $0.0 2 per share price was the original
price paid by selling shareholders and discuss the fact that this prohibits them
from making any profit on sales unless and until there is an active trading market.
Alternately, inc rease the fixed price and pay the additional filing fee.

4. Your principal executive office address is listed as 222 E. Jones Avenue, Wake
Forest, North Carolina 27587.  In the Contract Agreement filed as Exhibit 10.2 to
your Form S -1, Uptone Pictures, Inc.’ s office is listed as 704 Richland Bluff
Court, Wake Forest, North Carolina 27587.  However, Uptone Pictures list their
address as 222 E. Jones Avenue on their website.  Please explain to us why you
listed Uptone Pictures’ E. Jones Avenue address as your p rincipal executive office
address on the cover of the filing and why Uptone Pictures listed their office as
being on Richland Bluff Court for purposes of the Contract Agreement for
Production Services.

Registration Statement Cover Page

5. Please  provide the  telephone number for your agent for service.

6. The registration fee cannot be calculated in accordance with Rule 457(c) as there
is no market for the common stock.  Please revise the registration statement to
recalculate the registration fee in accordance with the appropriate rule.

Outside  Cover Page of the Prospectus

7. Please highlight the cross -reference to the Risk Factors section by prominent type
or another manner.   Refer to Item 501(b)(5) of Regulation S -K.

Summary Information  and Risk Factors , page 4

Business , page 4

8. The independent auditor’s report expresses substantial doubt about the company’s
ability to continue as a going concern.  Please disclose this information in this
section.  Additionally p lease disclose your monthly “burn rate” and the month you
will run out of funds  without the addition of capital .

9. On page 4 you state that you acquired “A Box for Rob” from an unrelated third
party.  Please tell us the name and principals of that party and any current or
previous personal or business relationships that Mr. Wilcken or Moving Box, Inc.
had with that party or its principals.

Andreas Wilcken, Jr.
Moving Box Inc.
September 7, 2010
Page 3

10. Refer to the second bullet on page 4.  Please revi se this bullet to clarify  that the
amount of the loan as of July 13, 2010 is $110,200.

11. Refer to t he third and four th bullet s on page 4 and the first bullet on page 5.
Please clarify whether the amount due under the Note will be paid back before or
after any payments made pursuant to the Production Agreement.   In this regard, it
appears that the last sentence of the f irst bullet on page 5 appears to conflict with
the fourth bullet on page 4.   Please note that there is similar conflicting disclosure
in the last paragraph on page 22 and the second and fourth paragraphs on page 23.

12. On page 4 you state that Uptone Picture s, Inc. (“Uptone Pictures”) is an unrelated
third party.  However, as noted in the comment above, it appears that you share
the same office as Uptone Pictures.  In addition, Upton Pictures’ website lists
Andreas Wilcken, the principal of Moving Box, Inc., and Michael Davis, the
principal of Uptone Pictures, as the two members of the company’s team.
Furthermore, it appears that Andreas Wilcken and Michael Davis are partners in a
firm named Seven Worldwide.  Given the observations noted above, please
explain  to us and in your filing all relationships between and among Uptone
Pictures, Moving Box, Inc., Mr. Wilcken, and Mr. Davis.

13. Please state that you have no binding contracts, agreements or commitments
regarding the distribution of the Movie.   Please also a dvise when you anticipate
that the movie will be ready for distribution.

The Offering, page 5

14. We note your disclosure that the current absence of a public market will make it
more difficult for a shareholder to sell shares of your comment stock.  We also
note your disclosure on pages 11 and 15 that your “shares should be considered
totally illiquid.”  Please revise your disclosure in this section so that it is
consistent with the disclosure on pages 11 and 15.

15. Please revise to clarify that no market make r has filed an application with FINRA
on your behalf.

16. Please reconcile your statement on page five that “ selling shareholders will not
offer their shar es per share until our shares  are quoted on the OTC Bulletin…”
with your statement on page two that “ selling shareholders will offer their shares
at $0.02 per share until our shares are quoted on the OTC Bulletin Board ….”

Andreas Wilcken, Jr.
Moving Box Inc.
September 7, 2010
Page 4

Financial Summary, page 5

17. Please revise your disclosure to clearly indicate that you reported losses for the
reporting periods end ed March 31, 2010 and June 30, 2010, by presenting the
disclosed amounts in parentheses.

Risk Factors, page 7

18. Please provide a risk factor discussing that you have no distribution deals and
may never enter into one.  We note your statement on page 23 that management
believes  “success is having a  distribution deal prior to production of the film.”

19. Please create a risk factor to discuss, to the extent material, the recent economic
conditions and what impact these current market conditions may have on yo ur
ability to start a business in the entertainment industry such as your future ability
to acquire any additional films.

20. Please create a risk factor that your  executive officer s are currently not receiving
any compensation a nd disclose what compensation they ultimately expect to
receive.  That will help investors evaluate the financial statements.

The person primarily responsible for managing our business, page 9

21. Please revise this risk factor to include disclosure regarding Mr. Seelbinder or
advise.  P lease also discuss in this risk factor whether there are any employment
agreements in place for Mr. Wilcken and Mr. Seelbinder.

Our primary management has no experience, page 10

22. Please quantify the anticipated costs of being a public company , such as you r
legal, accounting and other expenses, so that investors can better understand this
risk.

Investors may have difficulty in reselling their shares, page 11

23. Please revise here and on page 15 to list the states , if any,  where you intend to
register your se curities.   Additionally we note your statement that “ the manual
exemption is a non issuer exemption restricted to secondary trading transactions,
making it unavailable for issuers selling newly issued securities .”  Please revise to
disclose the effect of t his, including its effect on your ability to raise equity
through future issuances.

Andreas Wilcken, Jr.
Moving Box Inc.
September 7, 2010
Page 5

Selling Shareholders, page 13

24. Please revise your table on page 14 to provide all of the information required by
Item 507 of Regulation S -K such as the amount of securit ies owned by the selling
shareholder prior to the offering.  Additionally, p lease be advised that a person is
deemed to beneficially own stock held by his spouse and minor children.  We
note in this regard, many of the selling shareholder share the same la st name.
Please revise if necessary.

Plan of Distribution, page 15

OTC Bulletin Board Considerations, page 16

25. We note your disclosure in the last sentence of the first paragraph of this section.
Please  name counsel and provide an appropriate consent  to the extent this
disclosure constitutes a legal conclusion  or advise .

Description of Business, page 21

Development and Finance, page 22

26. Please revise this section to define the terms “Net Revenue” and “Net Profit.”
Please also revise your disclosure t o clarify in what order you will pay back each
of your obligations under the Royalty Rights Agreement, Wilcken Note and
Production Agreement and when you will begin receiving a ny of the revenues
from “A Box for Rob.”  Additionally, please revise your discl osure to discuss the
impact these agreements will have on your future profitability.

Production, page 23

27. Please revise to clarify the payments made to Uptone.  You state here that you
will pay $264,200 in addition to 50% of net profits.  But the agreemen t stipulates
$254,200.  Please also discuss the payments already made of $109,553.35, as
noted  on page five.

Distribution, page 23

28. Please clarify your Distribution discussion.  We note on page four that you plan to
“sell, lease, license…” your product, b ut your Distribution discussion does not
mention leasing.  Additionally, you appear to discuss selling and licensing
interchangeably in the fourth paragraph of the discussion.

Andreas Wilcken, Jr.
Moving Box Inc.
September 7, 2010
Page 6

Television Rights, page 24

29. Please remove reference to specific networks unle ss you have agreements
currently in effect.

Management’s Discussion and Analysis and Results of Operations, page 27

30. Please remove reference to Section 27A of the Securities Act and Section 21E of
the Securities Exchange Act, as these do not apply to you.

31. Please remove the language “and in our other reports” in the last sentence of the
third paragraph of this section or advise as to what other reports you are referring
to.

Overview, page 27

32. We note your disclosure in this section that “[f]inally having established access to
distribution channels sets Moving Box apart.”  This statement appears to conflict
with your disclosure elsewhere in your filing that you have no distribution
agreements.  Please revise your disclosure for consistency or advise.

Certa in Relationships and Related Transactions, page 30

33. Regarding the Wi lcken Note please state the amount currently outstanding, the
amount of principal paid  to date  and the amount of interest paid to date.   Refer to
Item 404(a)(5) of Regulation S -K.

Market for Common Equity and Related Stockholder Matters, page 31

Reports to Shareholders, page 33

34. Please advise as to why you will only file periodic reports through March 31,
2011.  Alternatively, please delete this language.

Executive Compensation, page 33

35. Please revise this section to include information regarding the compensation paid
to Mr. Seelbinder or advise as to why Mr. Seelbinder was omitted from this
section.

Andreas Wilcken, Jr.
Moving Box Inc.
September 7, 2010
Page 7

Audited Financial Statements for the period ended March 31, 2010

Notes to the Finan cial Statements

Note 6 – Related Party Transactions, page F -9

36. We note that your footnote disclosure does not discuss the “Related party
advances” in the amount of $37,600, which were outstanding as of March 31,
2010.  Please revise your disclosure, accor dingly.  In addition, tell us why the
balance as of March 31, 2010 was reflected as a liability in your audited financial
statements, but as “Additional paid -in capital” in your interim period financial
statements.  In this regard, please reconcile your di sclosure, as appropriate.

Note 7 – Subsequent Events, page F -9

37. In the “Subsequent Events” footnotes to both your audited and interim period
financial statements, you disclose that the borrowings from your President totaled
$100,210, subsequent to the re ceipt of $10,000 loaned on July 13, 2010.
However, based upon your disclosure elsewhere in your filing, it appears that the
borrowings from your President should have totaled $110,210, after you received
the $10,000 on July 13, 2010.  Please reconcile you r disclosure as appropriate.

Unaudited Financial Statements for the period ended June 30, 2010

Balance Sheet, page F -11

38. It appears that you have reported the $154,000 received in connection with the
sale of royalty rights to your movie as “Additional pa id-in capital” on your
balance sheet.  However, given that the counterparties to your royalty rights
agreement are entitled to repayment of the $154,000, before you make payments
to any of your company’s other investors or creditors, it appears that it may  be
more appropriate to report the $154,000 as a liability.  Please revise your
disclosure or advise.  In addition, given that the $154,000 appears to have been
received during the interim period ended June 30, 2010, please discuss the royalty
agreement in  the footnotes to the financial statements provided for that period.
Lastly, please revise your disclosure regarding your royalty agreement to clarify
whether (I) the counterparties are entitled to repayment of the amount of their
investment, as well as t he first $154,000 in net revenue received by Moving Box
or (II) the counterparties will be repaid their investment through receipt of the
first $154,000 in net revenue earned by Moving Box.  We do not believe that your
disclosure, as stated in Note 6 to th e financial statements for the period ended
March 31, 2010, is clear in this regard.

Andreas Wilcken, Jr.
Moving Box Inc.
September 7, 2010
Page 8

Statements of Operations, page F -12

39. Given that the “weighted average [number of] shares outstanding” was 4,500,000
shares for the period ended March 31, 2010, it is un clear to us why the weighted
average number of shares outstanding” for the interim and cumulative periods
ended June 30, 2010 would be 2,719,718 shares and 1,964,286 shares,
respectively.  In this regard, please revise your disclosure or advise.

Other

40. Please provide a currently dated consent from your independent public accountant
upon filing your amended registration statement.

Part II

Recent Sales of Unregistered Securities, page 39

41. Please revise this section to include all of the information require d by Item 701 of
Regulation S -K.

Exhibits, page 40

42. Please r emove the reference to Regulation SB.

Exhibit 2.1

43. We note that Exhibit 2.1 states that a copy of the Plan of Exchange is attached to
these minutes.  However, the Plan of Exchange does not appea r to be filed as part
of Exhibit 2.1.  Please refile Exhibit 2.1 to include the Plan of Exchange or
advise.

Exhibit 5.1

44. Please revise the first paragraph of the opinion so it sets for th the correct number
of common stock to be sold pursuant to