POULTON & YORDAN
ATTORNEYS AT LAW
RICHARD T. LUDLOW
December 10, 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 |
| Response letter dated October 15, 2007 |
| File No.: 0-50218 |
Dear Mr. Wojciechowski:
This letter is written in response to a staff comment letter dated November 30, 2007, from your office addressed to Bekem Metals, Inc. The Company will not complete its responses within ten business days from receipt of your letter and requests additional time to respond. The Company anticipates that it will file its response to your comment letter by no later than January 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 |
