| | |
GARY B. WOLFF, P.C. | |
COUNSELOR AT LAW | 488 Madison Avenue Suite 1100 New York, New York 10022 |
Tel: (212) 644-6446 Fax: (212) 644-6498 Email:wolffpc@nyc.rr.com |
April 26, 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 Four
File No.: 333-170393
Dear Mr. Dang:
Enclosed is Pre-Effective Amendment Four to the above Registration Statement. The changes are made in response to staff comments. The paragraph numbers below correspond to the numbered comments in your comment letter dated April 20, 2011.
General
1.
We have added the requested disclosure. The Company has had revenue for 13 consecutive years. The term “nominal” is undefined so we disclosed ranges.
Business
2.
We have added the requested disclosure inBusiness and have added a new Risk Factor #5.
If you have any questions or require anything further, please feel free to call me at 212-644-6446.
Sincerely,
/s/ Gary B. Wolff
Gary B. Wolff
cc:
Exclusive Building Services, Inc.