SecProbe.io

May 4, 2012
 Via E-mail

Anna C. Jones President and Chief Executive Officer B-Maven, Inc. 3272 Reynard Way San Diego, CA  92103
Re: B-Maven, Inc.
Amendment No. 4 to Registrati on Statement on Form S-1
Filed April 6, 2012
  File No. 333-176376

Dear Ms. Jones:

We have reviewed your registration statem ent and have the following comments.
 General

1. Since you appear to qualify as an “emerging growth company,” as defined in the
Jumpstart Our Business Startups Act, please di sclose on your prospect us cover page that
you are an emerging growth company and revise your prospectus to:

 Describe how and when a company may lose emerging growth company status;

 Briefly describe the various exemptions  that are available to you, such as
exemptions from Section 404(b) of the Sarbanes-Oxley Act of 2002 and Section
14A(a) and (b) of the Securities Exchange Act of 1934; and
 State your election under Sec tion 107(b) of the JOBS Act:

o If you have elected to opt out
 of the extended transition period for
complying with new or revised accounting standards pursuant to Section 107(b) of the Act, include a statement that the election is  irrevocable; or

o If you have elected to use the extend ed transition period for complying
with new or revised accounting standa rds under Section 102(b)(1), provide
a risk factor explaining that this election allows you to delay the adoption
of new or revised accounting standards that have different effective dates
for public and private companies until those standards a pply to private
companies.  Please state in your risk fact or that, as a result of this election,
your financial statements may not be comparable to companies that

Anna C. Jones B-Maven, Inc. May 4, 2012 Page 2

 comply with public company effective dates.  Include a similar statement
in your critical account ing policy disclosures.
 In addition, consider describing the extent to which any of these exemptions are available
to you as a Smaller Reporting Company.
 Prospectus Summary, page 4

2. We note your revised disclosure in the sevent h paragraph on page 4.  In the first sentence
of this paragraph, you state that “BMI has de veloped a full spectrum of skin care products
. . . .”  This statement appears to contradict  your other statements in this paragraph.  For
example, you reference that you are “currently  developing and test ing” your products,
and in the last sentence, you discuss qualities you expect your products to have “once
developed.”  Please revise th is paragraph, as well as your disclosure throughout the
prospectus, so that it accurately and consiste ntly reflects the current  stage of your product
development and operations.  In this regar d, we note other inconsistencies in the
prospectus including, but not limited to, your statement in the penultimate paragraph on
page 24 that you will “begin work on the product formulas” after the offering has been completed and proceeds have been received.

Risk Factors, page 6

 Risks Related to Our Common Stock, page 12

 You may have limited access to informati on regarding our business . . . , page 17

3. Please revise the disclosure in this risk f actor and on page 44 so that the shareholder
thresholds you reference reflect the changes made by the Jumpstart Our Business Startups
Act.
Use of Proceeds, page 17

4. It is unclear to us why you now state that  only $7,500, rather than $10,000, of the legal
fees will be paid if you collect the maxi mum offering proceeds.  Please clarify your
intended use of the remaining $2,500.
 The Offering, page 18

5. We note your response to comment three of our letter dated December 9, 2011.
Specifically, we note the only change in your “escrow arrangement” is  the change in the
“escrow agent.”  Accordingly, we are still una ble to agree with your conclusion that this
arrangement for Quick Law Group, P.C. to hold offering proceeds is properly characterized as an escrow arrangement.  Please revise your disc losure accordingly.

Anna C. Jones B-Maven, Inc. May 4, 2012 Page 3

 Management’s Discussion and Analysis  or Plan of Operation, page 22

 Operations, page 22

6. We note your response to comment four of our letter dated December 9, 2011, and we
reissue the comment in part.  Please provi de a timeline for the completion of your
business plan assuming you raise 75%, 50% , 25%, and 10% of the required funding.

7. We note your response to comment five of our letter dated December 9, 2011.
Specifically, we note your statement on page 24 that you can maintain the business for at
least 12 months in part thr ough short term loans from friends and family members which
you “currently have in place.”  Please either clarify what you mean by “currently have in
place” or remove this language as it gives th e appearance that you have commitments for
financing from friends and fam ily members.  In this regard, we note the apparent
inconsistent disclosure in which you state that you curre ntly have “no sources of
financing and no commitments for financing.”   Additionally, please disclose that you do
not and will not accrue compensation for Ms.  Jones’ services, as indicated in your
response to the comment.
 Seasonality, page 27

8. On page 8, we note you discuss seasonality during the winter.  Please provide similar
disclosure in this section.
 Business, page 27

 Proposed Products, page 29

9. In the fourth paragraph, you refer to fiscal  year 2012 when it appears you mean fiscal
year 2013.  You make a similar statement in th e last paragraph on page 30.  Please revise
your disclosure as appropriate.
 Certain Relationships and Re lated Transactions, page 35

10. Please identify Quick Law Group, P.C. as a promoter.  Refer to the definition of
“promoter” in Rule 405 of Regulation C.
 Plan of Distribution, page 39

11. We note your response to comment nine of  our letter dated December 9, 2011.  Please
disclose in the prospectus that you do not have a formal arrangement or understanding
with the market maker you identify as having agreed to file an a pplication with FINRA
on your behalf.

Anna C. Jones B-Maven, Inc. May 4, 2012 Page 4

 Exhibits, page II-2

12. Please tell us why you continue to include th e opinion provided by Ga ry B. Wolff, P.C.,
the original subscription agreement, and the or iginal escrow agreement as exhibits to the
registration statement.

You may contact Dale Welcome at (202) 551-3865 or Kevin St ertzel at (202) 551-3723 if
you have questions regarding comments on the fina ncial statements and related matters.  Please
contact Jessica Dickerson at (202) 551-3749 or me at (202) 551-3397 with any other questions.

Sincerely,
   /s/ Jay Ingram
Jay Ingram Legal Branch Chief
cc: Via E-mail

 Jeffrey M. Quick, Quick Law Group PC