Denis Frawley
416.594.0791, ext. 113
dfrawley@olflaw.com
September 29, 2010
VIA EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, DC
20549-7010
Attention: Douglas Brown, Division of Corporation Finance
Telephone Number: (202) 551-3365
Telecopier Number: (703) 813-6982
Dear Mr. Brown:
Re: | Bio-Carbon Systems International Inc., formerly known as ABC Acquisition Corp. 1501 |
I am writing as legal counsel to Bio-Carbon Systems International Inc.
We have received your comment letter dated September 15, 2010 regarding the following filings by ABC Acquisition Corp. 1501 (now known as Bio-Carbon Systems International Inc. (the “Company”)): a Form 10 filed October 28, 2009; a Form 10-K filed April 6, 2010; a Form 8-K filed June 7, 2010; and a Form 10 filed August 16, 2010. We are in the process of collecting additional information and preparing answers to your comments. We expect to provide you with a response, as well as file amended filings, by October 8, 2010.
Please note that questions regarding the Form 10 filed October 28, 2009 and the Form 10-K filed April 6, 2010 will be answered by Mr. Grady Thrasher, who was a legal counsel to the Company at that time.
Yours truly,
Ormston List Frawley LLP
/s/ Denis Frawley
Denis Frawley
cc: Luc Duchesne
DF:em