High Performance Beverages CORRESP Correspondence with SEC

Gary B.Wolff, P.C.

488 Madison Avenue, Suite 1100 New York, New York 10022

COUNSELOR AT LAW______________________________________________________________________________

Tel: (212) 644-6446 Fax: (212) 644-6498 Email: wolffpc@nyc.rr.com

January 10, 2011

Duc Dang

Senior Counsel

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Exclusive Building Services, Inc. (the “Company” or “Issuer”)

Registration Statement Form S1/ Pre-Effective Amendment One

File No.: 333-170393

Dear Mr. Dang:

Enclosed is Pre-Effective Amendment One to the above Registration Statement. The changes are made in response to staff comments to the initial Registration Statement and to make appropriate updates. The paragraph numbers below correspond to the numbered comments in your comment letter dated December 3, 2010.

General

Section (a) (2) of Rule 419 defines a blank check company as a “development stage company that has no specific business plan or purpose or has indicated that its business plan is to engage in a merger or acquisition with an unidentified company or companies…”

The Company has had a specific business plan and operations since its inception in 1997. It has not generated large amounts of revenues but has consistently generated revenues using the same mode of operations for 13 years. For these reasons, it is not a blank check company.

Cover Page of Prospectus

The requested disclosures have been made.

Prospective Summary

About Exclusive Building Services, Inc.

We added a brief reference to the “make ready” aspects of the business. We do not believe that it is appropriate to make further emphasis of this component at this time because construction of new and renovation of old office facilities are at extremely low levels meaning that there is currently an extremely low potential demand for “make ready” services in the current economic climate.

We have added the requested disclosure. Our day-to-day operations have remained the same as an incorporated entity as they had when we were a DBA. The legal structure is different but the operations are unchanged.

Risk Factors

Risk Factor #12 has been edited to provide the requested disclosure.

We have made the requested revisions.

The disclosure concerning “control share acquisitions” relates to an aspect of Nevada law which does not apply to us unless or until we have 200 shareholders of record with at least 100 of these having addresses in Nevada. However, we have expanded Risk Factor #18 to provide additional disclosures.

Risks Related to the Business

We have expanded Risk Factor #7 to provide the requested disclosure.

EBS is and will continue to be completely dependent on the services…

The requested disclosure has been provided in Risk Factor #7.

There are significant potential conflicts of interest…

10.

We have eliminated references to the mitigating factor.

We intend to become subject to the periodic reporting requirements…

11.

We have made the requested disclosure.

Patricia G. Skarpa, our chief executive officer…

12.

Risk Factor #7 has been expanded.

The costs of being a public company…

13.

We deleted this Risk Factor.

Risks Related to our Common Stock

Currently there is no established public market…

Any market that develops in shares for our common stock…

14.

We have made the requested edits and modifications to these Risk Factors and toMarket Securities.

Use of Proceeds

15.

The requested disclosure has been made.

16.

The reference to minimum has been eliminated.

17.

Disclosure has been added to deal with the case of all registered shares not being sold.

The Offering

18.

There is disclosure on the Cover Page and The Offering that “There is no minimum number of shares that must be sold by us for the offering to close, and we will retain the proceeds from the sale of any of the offered shares that are sold.”

Dilution

19.

The requested disclosure has been made.

Market for Securities

20.

The disclosure has been revised.

Note Regarding Forward Looking Statements

21.

The requested disclosure has been made.

Management’s Discussion and Analysis of Financial Condition or Results of Operation

22.

The requested disclosure has been made.