POULTON & YORDAN
ATTORNEYS AT LAW
RICHARD T. LUDLOW
April 1, 2008
Mark Wojciechowski
Staff Accountant
United States Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 7010
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Bekem Metals, Inc. |
| Form 10-KSB for the Fiscal Year Ended December 31, 2006 |
| Filed April 2, 2007 |
| Form 10-KSB/A for the Fiscal Year Ended December 31, 2006 |
| Filed March 20, 2008 |
| File No. 0-50218 |
Form 10-KSB/A for the Fiscal Year Ended December 31, 2006
Report of Independent Registered Public Accounting Firm, page F-2
1. | The report from your independent public accounting firm on your consolidated financial statements includes an explanatory paragraph that refers to Note 13, which describes the effects of the restated financial statements. However, we note the date of such report has not been revised to indicate that this Note is audited. Please advise if such Note is audited, and if so, obtain and file a revised report from your independent public accounting firm to indicate such Note is audited. |
This letter will confirm that Note 13 is audited. Simultaneous with the filing of this letter, the Company is filing a Second Amendment to its Annual Report on Form 10-KSB/A for the year ended December 31, 2006 indicating the date that Note 13 is audited and to provide a properly dual dated report from the Company’s independent registered public accounting firm.
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 |
Mr. Mark Wojciechowski
April 1, 2008
Page 2
Thank you for your assistance in this matter. If you have any questions or require additional information, please contact me directly.
| Very truly yours, |
| POULTON & YORDAN |
| Richard T. Ludlow |
| Attorney at Law |
