SecProbe.io

February 2, 2015
Via E -mail
Mr. Ali Kharazmi
Chief Executive Officer
Bling Marketing, Inc.
720 Paularino Avenue
Costa Mesa, California  92626

Re: Bling Marketing, Inc.
 Form 8-K
Filed January 6, 2015
File No. 333-192997

Dear Mr. Kharazmi :

We have reviewed your filing an d 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 within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstance s or do not
believe an amendment is appropriate, please tell us why in your response.

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

Form 8 -K filed January 6, 2015

General

1. We note disclosure on page 3 that you entered the Agreement and Plan of Merger on
December 26, 2014 and closed on the transaction on December 29, 2014, but you did not
file the Form 8 -K relating to this transaction until Januar y 6, 2015.  In future filings,
please file or furnish a Form 8 -K within four business days after the occurrence of the
event pursuant to Form 8 -K instructions.  Note that untimely filings such as this render
you ineligible to use Form S -3 for a period of t welve months plus any portion of a month
immediately preceding the filing of a registration statement.

2. Under an appropriate subheading, please describe any related party transactions that are
required to be disclosed under Item 404 of Regulation S -K.  N ote that the threshold for
disclosure is the lesser of $120,000 or one percent of the average of NuGene’s total assets
at year end for the last two completed fiscal years.

Ali Kharazmi
Bling Marketing, Inc.
February 2, 2015
Page 2

 Item 1.01 Entry Into a Material Definitive Agreement, page 3

3. We note disclosure tha t each recipient of the stock dividend will receive 14.04 additional
shares of common stock for every share of common stock held.  However, section 2.1(c)
of the Agreement and Plan of Merger filed as Exhibit 2.1 assumes that the company has
given effect to  a 15.04 to 1 stock dividend in setting the conversion ratio for the merger.
Please revise to reconcile these inconsistencies.

4. We note disclosure of the issuance of 1,917,720 shares of your series A Preferred stock.
Please disclose here that the preferr ed stock is convertible into common stock at a ratio of
one to one, has the right to elect a majority of the board of directors and has three votes
for every vote available to the common stock.

5. Please disclose that this is a reverse merger transaction.  A lso, please describe the terms
of the merger in this section, including the number of common and preferred shares
issued as consideration to holders of both common and preferred shares of NuGene
International, Inc.

Item 2.01 Completion of Acquisition of D isposition of Assets, page 4

6. We note your summary of the Agreement and Plan of Merger on page 3.  Please revise to
provide information pursuant to Item 2.01(c) and (d) of Form 8 -K including:

 The identity of the persons from whom the common shares of Bling Marketing,
Inc. were acquired and the nature of any material relationship between such
persons and the registrant or any of its affiliates, or any director or officer of the
registrant, or an y associate of any such director or officer;

 The nature and amount of consideration given or received for the all of the issued
and outstanding shares of Bling Marketing, Inc. including the number of shares of
Bling Marketing, Inc. you received, as well as all of the consideration given for
such shares. In this regard, we note that Section 4.6 of the Agreement and Plan of
Merger filed as Exhibit 2.1 contemplates a warrant for the purchase of up to
500,000 shares of common stock at a price of $2.50 per sha re.  Please clearly
describe the identity of the person or persons in possession of the warrant and the
consideration given or  received for such warrant; and

 The formula used to determine the amount of consideration.

7. Please revise to discuss whether the  board and shareholders of Bling Marketing, Inc.
approved the Share Exchange Agreement and how approval was obtained.

Ali Kharazmi
Bling Marketing, Inc.
February 2, 2015
Page 3

 Item 3.02 Unregistered Sales of Equity Securities, page 4

8. Please revise your disclosure to provide the dates of sale of your securitie s sold, the
consideration, and the terms of conversion or exercise of your warrants and automatic
conversion promissory notes pursuant to Item 3.02(a) of the Form 8 -K Instructions and
Items 701(a), (c) and (e) of Regulation S -K.

Item 5.01 Changes in Cont rol of Registrant, page 5

9. We note disclosure that eight prior shareholders will own approximately 66.47% of the
outstanding common stock and that two shareholders voting as a class are empowered to
elect a majority of the board of directors.  Please revis e to disclose the identity of the
persons who acquired control, the basis of the control, including the percentage of
“voting” securities of the registrant now beneficially owned by the persons who acquired
control and identify the person(s) from whom cont rol was assumed. See Items 5.01
(a)(1), (3) and (6) of the Form 8 -K Instructions.

Item 8.01 Other Events, page 6

Description of Business, page 6

History, page 6

10. Please disclose in this section that Bling Marketing, Inc. was a shell company until you
changed your status as disclosed in your Form 8 -K filing on September 11, 2014.

The NuGene Industry and the Overall Market, page 7

NuGene History, page 7

11. We note the disclosure on page 28 in the risk factor “Because we have a limited operating
history. . .”.  Please revise this section to clearly describe that you are an early stage
company and your operations to date have been primarily focused on your formation, the
hiring of your management team, etc.

12. Please revise this section to clearly describe your  current operations, versus your intended
operations.  We note disclosure that during the first nine months of 2014 you
“distributed” product nationally through medical offices and medical spas.  We also note
disclosure on page 22 in the risk factor “We de pend on wholesalers for the majority . . .”
that 68% of your cosmeceutical revenues were from an affiliate and 32% from select
wholesale distributor(s).

13. Please revise this section to clearly describe your customers.  Please also clearly disclose
the geogr aphic area in which you are selling your products.

Ali Kharazmi
Bling Marketing, Inc.
February 2, 2015
Page 4

 License with Kathy Ireland Worldwide, Inc., page 9

14. Please disclose that you are required to submit a business plan for the review and
approval by the licensor within 90 days of the agreement and that if  you have not
launched products under this agreement by April 15, 2015, the licensor may terminate the
agreement.  Please also clearly state whether you have products to market under this
agreement, if so, please describe such products, describe the status  of the submission and
approval of your business plan by the licensee and whether you intend to launch products
by April 15, 2015.

Overview, page 10

15. Please revise to provide a section on management’s discussion and analysis that is fully
responsive to th e requirements of Item 303(A)(1) -(3) of Regulation S -K. For the liquidity
discussion, at a minimum, you should: i) discuss the sources and amounts of cash you
will need to sustain operations for the next twelve months; ii) quantify the extent to
which you are currently using funds in your operations on a monthly basis; and iii)
discuss your long -term liquidity needs as discussed in Section 501.03.a of the
Codification of Financial Reporting Policies.

Our Products, page 12

16. We note the description of variou s Skincare and Hair care products.  Please describe the
stage of development of these products and clearly explain whether these are your current
or intended products. Please also identify any products that are licensed from third
parties.

Pharmaceutical Products, page 13

17. We note disclosure that you have initiated preclinical FDA work for a new topical drug
for the treatment of burns.  Please briefly discuss the steps that will be necessary to
develop and market this drug and the timeframe for when you ex pect to take those steps.
Throughout disclosure elsewhere, please also distinguish the pharmaceutical products,
which do not appear to be ready to market, from your cosmeceutical products.

Management and Directors, page 46

18. We note that disclosure of the  names and titles of your key management on page 25 in
your risk factor “If we are unable to attract . . .” are not consistent with the names and
titles of your management in this section.  We also note disclosure on page 6 that Ms.
Kurland submitted her r esignation as director.  Further, we note disclosure here that Ms.
Kurland is named as a director.  Please revise to make these disclosures consistent.

Ali Kharazmi
Bling Marketing, Inc.
February 2, 2015
Page 5

 M. Saeed Kharazmi, page 47

19. Please revise to describe the terms “UCR”,  “HS”, and “UCR Health”.

Executive Compensation, page 49

Summary Compensation Table, page 49

20. We note your disclosure that no officer received total annual compensation in excess of
$100,000 during the years ended December 31, 2013 and 2012.  However, you must still
disclose comp ensation for your principal executive officer, regardless of compensation
level.  Please see Item 402(m)(2) of Regulation S -K and the instructions thereto.

Exhibits, page 53

21. We note that you have not filed signed versions of a number of your exhibits.  P lease file
signed and completed versions of exhibits 2.1, 4.1, 10.1, 10.2, 10.5 and 10.6, with your
next amendment.  Please also file a dated exhibit 10.3.

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 Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny 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.

 In responding to our comments, please provide  a written statement from the co mpany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

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

Ali Kharazmi
Bling Marketing, Inc.
February 2, 2015
Page 6

 You may contact Jenn Do, Staff Accountant at (202) 551 -3743 or, in her absence,
Terence O’Brien, Accounting Branch Chief  at (202) 551 -3355  if you have questions regarding
comments on the financial statements and related matters.  Please contact Sherry Haywood, Staff
Attorney at  (202) 551 -3345  or, in her absence,  me at (202) 551 -3760  with any other questions.

Sincerely,

 /s/ Pamela Long

 Pamela Long
Assistant Director

cc: Via E -mail
 Aaron Grunfeld , Esq.