Independent Film Development Corporation
190 N. Canon Drive
Suite 420
Beverly Hills, CA 90210
310-275-0089
April 29, 2008
United States
Securities and Exchange Commission
Division of Corporate Finance
Washington, D.C. 20549
Attn: Tom Kluck, Branch Chief
Re: Independent Film Development Corporation
Registration Statement on Form 10
File No. 0-53103
Dear Mr. Kluck,
The company is in receipt of your further comments of April 29, 2008. Please be advised that we did consider the provisions of Rule 8-04 of Regulation S-X with regard to business combinations with relation to the acquisition of Signature Entertainment, LLC. At present, Signature Entertainment, LLC is a limited liability company that was formed by Independent Film Development Corporation in 2008, with no assets, no liabilities, and nothing but a plan of operations. The company’s only investment in Signature Films, LLC is its organizational costs of $175. It has no reported income or loss, and no par value with which to even establish a book value.
Applying the tests of Rule 8-04b to Signature Films, LLC, the impact is significantly less than 20%. We intend to account for the formation of the subsidiary on our quarterly filing on or before May 15, 2008.
Please be further advised that the Company is responsible for the adequacy and accuracy of the disclosures in the filing. Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking an y action with respect to the filing; and the Company may not assert staff comments as a defense ion any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Sincerely yours,
KENNETH G. EADE