LAWLER & ASSOCIATES
a professional law corporation
41877 Enterprise Circle N., Suite 220
Temecula, California, 92592
Telephone: 951-506-8888
Facsimile: 951-506-8877
W. SCOTT LAWLER, ESQ.
Admitted in California
November 10, 2005
Via Edgar and Overnight Courier
Mail Stop 0511
United States Securities and Exchange Commission
450 Fifth Street, N.W.,
Washington, D.C. 20549
Attention: ___Pamela A. Long– Assistant Director
RE:
Major Creations Inc.
Registration Statement on Form SB-2/ Amendment No. 4
File Number: 333-122870
Dear Ms. Long:
Please find enclosed herewith three (3) clean copies and three (3) redlined copies of Amendment No. 4 to Major Creations Inc.’s registration statement on Form SB-2/A.
Below are the comments from your comment letter regarding Major Creations’ Form SB-2/A filing, each followed by Major Creations’ responses thereto.
General
Comment
1. In the cover letter accompanying your next amendment, please respond to comments 8 and 9 of our September 12, 2005 letter. Your cover letter dated October 7, 2005 has no such response.
Response
We apologize for this oversight. The responses that should have been included in the cover letter should have been as follows:
8. We have added the disclosure requested by this comment.
9. We have added the identification of the principal financial officer and principal accounting officer, as noted by this comment.
Signatures
Comment
2. We reissue comment 9 from our September 12, 2005 letter. Form SB-2 requires you to identify the principal financial officer as well as the principal accounting officer or controller. If one person is serving in both capacities, please identify this person as principal financial officer and principal accounting officer or controller. Please refer to Instruction 1 for signatures on Form SB-S and revise the signature page.
Response
We have added the identification of the principal financial officer and principal accounting officer, as noted by this comment. This was added to Amendment No. 3 but somehow the identification of principal accounting officer was dropped before Amendment No. 3 was filed. We have assured that all necessary identifications are provided in this Amendment No. 4.
Sincerely,
/s/ W. Scott Lawler
W. Scott Lawler, Esq.
