POULTON & YORDAN
ATTORNEYS AT LAW
RICHARD T. LUDLOW
September 28, 2007
Mark Wojciechowski
Staff Accountant
United States Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 7010
Washington, D.C. 20549
| Re: | Bekem Metals, Inc. |
Form 10-KSB for the Fiscal Year Ended December 31, 2006
| Filed on April 2, 2007 |
| Form 10-Q for the Quarterly Period Ended June 30, 2007 |
| Filed on August 14, 2007 |
| File No.: 0-50218 |
Dear Mr. Wojciechowski:
This letter is written in follow up to our letter dated September 13, 2007. In that letter, we informed you that Bekem Metals, Inc. (the “Company”) would not complete its responses to the staff’s comment letter dated September 6, 2007, within the ten business days set forth in said letter. In our letter of September 13, 2007, we indicated that the Company anticipated that it would file its response to the staff’s comment letter by October 1, 2007. The Company will not file its response by October 1, 2007. Rather, the Company now anticipates it will file its response by no later than October 15, 2007.
| If you have any questions, please contact me directly. |
| Very truly yours, |
| POULTON & YORDAN |
| Richard T. Ludlow |
| Attorney at Law |
| POULTON & YORDAN | TELEPHONE: 801-355-1341 |
| 324 SOUTH 400 WEST, SUITE 250 | FAX: 801-355-2990 |
| SALT LAKE CITY, UTAH 84101 | POST@POULTON-YORDAN.COM |
