GLOBAL GSM SOLUTIONS INC.
204 West Spear Street
Carson City NV 89703
Tel: (775) 636-6986, Fax:(775) 245-3048
July 26, 2010
United States
Securities and Exchange Commission
Washington, DC 20549-7010
Attention: Dorine H. Miller
Re: Global GSM Solutions, Inc.
Amendment No. 3 to
Registration Statement on Form S-1
Filed: July 14, 2010
File No.: 333-165929
Dear Ms. Miller:
In response to your letter dated July 16, 2010 which included comments regarding our Amendment No. 3 to Registration Statement on Form S-1 filed on July14, 2010, we have prepared the following responses:
General
Comment 1: We have reviewed your response to prior comment two from our letter dated June 17, 2010. Since you have now presented financial statement for the period ended April 30, 2010, please update the information you have presented throughout the filing to also be as of April 30, 2010. For example, you should update your MD&A as well as the information presented on page 14 related to dilution.
In response to this comment, the Company has updated the information throughout the filing.
Financial Statements for the Period Ended April 30, 2010
Balance Sheets, page 44
Comment 2: The column heading of your January 31, 2010 balance sheet indicates that these amounts have been audited. Since none of the amounts are covered by an audit report when they are presented in your interim financial statements for the period ended April 30, 2010, you should not refer to them as being audited. Please revise.
In response to this comment, the Company has revised its interim financial statements for the period ended April 30, 2010.
Please direct any further comments or questions you may have to our President, Mr. Gennady Fedosov at:
Facsimile No.: (775) 245-3048
Thank you.
Sincerely,
/S/_Gennady_Fedosov
Gennady Fedosov, President
