SecProbe.io

January 13, 2014

Via E -mail
Dena  Kurland
Chief Executive Officer
Bling Marketing, Inc.
150 West 46th Street, Suite 5R
New York, New York 10036

Re: Bling Marketing, Inc.
Registration Statement on Form S -1
Filed December 20, 2013
  File No. 333-192997

Dear Ms . Kurland :

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
understand 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 appropri ate, 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. Your disclosure indicates that you are a d evelopment stage company that intends to
engage in the business of marketing affordable jewelry. It appears that your proposed
business may be commensurate in scope with the uncertainty ordinarily associated with a
blank check company. Please revise your d isclosure throughout your registration
statement to comply with Rule 419 under the Securities Act of 1933, as amended, in view
of the following:

 Your disclosure indicates that you are a development stage company issuing penny
stock.

 You have no revenues,  and no contracts or agreements with customers or suppliers
and have conducted little business activity.

Dena Kurland
Bling Marketing, Inc.
January 13, 2014
Page 2

  You have no assets, except for $500 in cash.

Please revise the registration statement to ensure it complies with Rule 419 and
prominently disclose t hat you are a blank check company. Alternatively, please provide
us a detailed analysis addressing each of the issues described above in explaining why
you believe the company is not a blank check company.

2. Please provide us with your analysis as to whethe r you are a shell company, as defined in
Rule 405 under the Securities Act. In this regard, we note that you appear to have no or
nominal operations, assets consisting of any amount of cash and cash equivalents and no
or nominal other assets. If you conclu de that your company is a shell company, please
revise your prospectus , including, but not limited to, the prospectus cover page,  to
disclose that you are a shell company and further disclose the consequences of that status,
such as the restrictions on you r ability to use registration statements on Form S -8, the
limitations on the ability of your security holders to use Rule 144 and the potential
reduced liquidity or illiquidity of your securities.

3. Please supplementally provide us with copies of all writte n communications, as defined
in Rule 405 under the Securities Act, if any, that you, or anyone authorized to do so on
your behalf, present to potential investors in reliance on Section 5(d) of the Securities
Act, whether or not they retain copies of the co mmunications. Similarly, please
supplementally provide us with any research reports, if any, about you that are published
or distributed in reliance upon Section 2(a)(3) of the Securities Act of 1933 added by
Section 105(a) of the Jumpstart Our Business St artups Act by any broker or dealer that is
participating or will participate in your offering.

Prospectus Cover Page

4. Please revise your disclosure to clarify that because there is no minimum to your
offering, if you fail to raise enough capital to commence operations, investors could lose
their entire investment and will not be entitled to a refund.

5. Please clarify whether the offering termination date is April 30, 2014 (page 4 ) or
November 30, 2014 (page 6) and use a consistent date throughout the filing.  In addition,
please revise your disclosure to clarify whether you reserve the right to extend the
offering beyond the termination date . If you reserve such right, please indicate how you
will notify investors of any extension. Please make conformi ng revisions throughout your
prospectus.

6. Please disclos e on the prospectus cover page that your auditor has expressed substantial
doubt as to your ability to continue as a going concern.

Dena Kurland
Bling Marketing, Inc.
January 13, 2014
Page 3

 7. Please disclose on the prospectus cover page the minimum number of shares needed to
generate sufficient proceeds to enable you to implement your business plan within the
next twelve months.

Prospectus Summary, page 6

Operations, page 6

8. Please disclose, if true, that you have not yet commenced operations and have not yet
generated any revenues.

Risk Factors, page 8

9. Please include a risk factor to address any risks that result from the structure of your
offering, such as the lack of an escrow account.

10. Please include a risk factor to address any risks that result fro m Ms. Kurland owning a
majority of your common stock. Please provide the percentage that Ms. Kurland currently
owns and the percentage of common stock she will own if all the shares registered as part
of this offering are sold.

We cannot offer any assura nce as to our future financial results, page 8

11. Please revise your disclosure to quantify, to the extent practicable, the amount of capital
you need to continue as a going concern or explain to us why you feel such disclosure is
not required.

Description of Business, page 15

12. We note in this section your use of terms that appear to be industry -specific jargon. For
example, you use phrases such as “vertical outlets” and “Gram. Dwt.” Please revise to
provide context for these terms so a reader not familiar w ith your industry can understand
your use of these terms.

13. Please clarify the current status of your operations. In this regard, it is unclear whether
you have finalized any of your products or completed any sales. For example, w e note
your disclosure that  “[you] ship [y]our products in bulk to [y]our wholesale distributors”
and that “ [you] have no contracts with any of [y]our customers,” on page 18.

Environmental Matters, page 19

14. We note your disclosure that you “have an ongoing compliance program to ens ure that
[y]our manufacturing processes are in compliance with environmental rules and
regulations.” Please disclose the costs related to your ongoing compliance program. Refer

Dena Kurland
Bling Marketing, Inc.
January 13, 2014
Page 4

 to Item 101 (h)(4)(xi) of Regulation S -K.  In addition, please revise your discl osure here,
and elsewhere as necessary, to clarify whether or not you engage in any manufacturing
activity.

Use of Proceeds, page 20

15. You indicate in the second sentence under this heading that you expect offering expenses
of $34,039; however, your tabula r presentation of the use of proceeds indicates that you
expect offering expenses of $25,500.   Please revise your filing to disclose a consistent
amount of expected offering expenses throughout your filing.

16. Please revise this section, to clarify the minim um amount of offering proceeds needed for
you to be able to implement your plan of operations. In this regard, we note your
disclosure that “[o]ther business activities will only be pursued if we raise at least
$25,000” on page 16, that your ability “to co ntinue as a going concern is dependent on
your ability to raise at least $125,000 through this offering” on page 25, and that “[y]our
current cash balance is estimated not to be sufficient to fund [y]our current operations,”
on page 23.

Dilution, page 21

17. Please revise your table showing dilution to reflect that your net tangible book value per
common share before the offering is -$0.0002.   In this regard, your current disclosure
presents a positive number instead of a negative number.

Management’s Discu ssion and Analysis, page 22

Plan of Operations, page 23

18. We note your disclosure that if you do not raise at least $25,000 you will use the
available funds to complete the activities listed on page 24. However , we note your
disclosure on page 20 that you will need “to raise at least $62,500” to complete the same
activities  that are  listed on page 24 . Please revise your disclosure to ensure consistency
throughout your filing.

19. We note your disclosure on page 19 that the first four months of your office leas e are free
of rent. Please  clarify in  this section,  if the lease expense to be incurred after the first four
months is included in your ongoing estimate of expenses .

20. We note your statement elsewhere in the filing that you “began working with
manufacturers  to put together [y]our jewelry line since the beginning of October
2013.”   Please revise your plan of operations to explain in detail what you have
accomplished in this regard and any remaining steps necessary to obtain jewelry from

Dena Kurland
Bling Marketing, Inc.
January 13, 2014
Page 5

 suppliers.   Your discl osures should clarify whether you have obtained any materials from
any suppliers or manufacturers as of the most recent practicable date, and if not, clearly
state this.

21. You refer elsewhere in your filing to anticipated customers including retailers and
jewelry wholesalers.   Please revise your plan of operations to explain in detail any steps
you have taken to secure customers and any indications of interest you have received
from potential customers as of the most recent practicable date.   Please elabor ate on your
plan to sell to both retailers and wholesalers and the steps necessary to achieve
this.  Please also revise your disclosure to clearly state whether you have made any sales
of the most recent practicable date.

Critical Accounting Policies and Estimates, page 25

22. Similar to your disclosure on page 13, please disclose here that you have elected to opt
out of the extended transition period for complying with new or revised accounting
standards pursuant to Section 107 of the JOBS Act, and include a  statement that this
election is irrevocable.

Involvement in Certain Legal Proceedings, page 28

23. Please revise this section to cover a ten year period. In this regard, we note your
disclosure only covers the past five years. Please refer to Item 401(f) of  Regulation S -K.

Item 15. Recent Sales of Unregistered Securities, page 48

24. Please expand your disclosure regarding the October 31, 2013 sale of common stock to
Ms. Kurland to indicate the section of the Securities Act or the rule of the Commission
under which exemption from registration was claimed and state briefly the facts rel ied
upon to make the exemption available. Please refer to Item 701(d) of Regulation S -K.

Financial Statements for the Period Ended October 31, 2013, page 35

25. Please update your financial statements, as necessary, to comply with Rule 8 -08 of
Regulation S -X.

Signatures

26. Please revise the signature section to identify the principal financial officer, principal
executive officer and principal accounting officer. Please see Instruction 1 to  Signatures
on Form S -1.

Dena Kurland
Bling Marketing, Inc.
January 13, 2014
Page 6

Exhibit 5.1

27. We note that counsel state s that “[t]his opinion opines upon Colorado law, including
Colorado Constitution, all applicable provisions of the statutory p rovisions, and reported
judicial decisions interpreting those laws.” However, the registrant is incorporated in
Nevada. Please hav e counsel revise the legality opinion to state that the opinion is based
on the laws of the State of Nevada. Please refer to Section II.B.3.b of Staff Legal
Bulleting No.19.

28. Please have counsel explain to us why the assumptions in the second paragraph re garding
compliance with the various laws identified are necessary to render the required opinion
or, in the alternative, please ask counsel to remove these assumptions from the opinion.

We urge all persons who are responsible for the accuracy and adequacy  of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s  disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement please provide  a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company  may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of  1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date o f the
registration statement.

Dena Kurland
Bling Marketing, Inc.
January 13, 2014
Page 7

 You may contact Robert Babula , Staff Accountant , at (202) 551 -3339 or Jennifer
Thompson, Accounting Branch Chief , at (202) 551 -3737 if you have questions regarding
comments on the financial statements and related matters .  Please contact Jennifer Ló pez, Staff
Attorney,  at (202) 551 -3792, Dietrich King, Legal Branch Chief, at (202) 551 -3338  or me at
(202) 551 -3720  with any other questions.

Sincerely,

 /s/ Dietrich A. King for

Mara L. Ransom
Assistant Director