MATTHEW MCMURDO, ESQ. Attorney-At-Law Matthew C. McMurdo | 917 318 2865 | matt@nannaronelaw.com | Suite 6D 140 West 57th Street New York, NY 10019 |
October 9, 2012
Via Edgar
United State Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, DC 20549
| Attention: | John Reynolds, Assistant Director |
| Adam F. Tuck |
| Re: | BLVD Holdings, Inc. | ||
| Amendment No. 1 to | |||
| Registration Statement on Form S-1 | |||
| Filed August 17, 2012 | |||
| File No. 333-183370 |
Dear Mr. Reynolds:
We are filing an Amendment No. 2 to the Registration Statement on Form S-1/A (the “Registration Statement”) in response to your recent review letter addressed to M. Ann Courtney, President of BLVD Holdings, Inc. (“BLVD”), dated September 17, 2012 (the “SEC Letter”). This response letter, along with the amended Registration Statement, addresses the concerns you have expressed
BLVD has further overhauled its business plan since the filing of Amendment No.1 to the Registration Statement. BLVD has decided to focus exclusively on the production, development and sale of television film scripts. The Nature of Business has been revised to clarify that BLVD is in the specific business of producing and developing scripts for film and television. We have removed all of the wording from the Form S-1 that would give the mistaken impression that the Company has not determined a specific line of business or that would give the false impression that the Company is a blank check company. BLVD is currently developing multiple film scripts and will be looking to add a screenplay writer to its employ. BLVD need not comply with Rule 419 under the Securities Act of 1933 because, as you’ll note in the amended Registration Statement, BLVD is not a blank-check company. BLVD has further defined and focused its business operations. BLVD will no longer be looking to acquire unidentified assets in multiple industries. BLVD has undertaken operations and received revenue in script production and development. BLVD intends to focus on such business for the foreseeable future. We hope this letter and the amendments we made to the Registration Statement address your concerns.
Matthew McMurdo, Esq.
New York
Please direct your correspondence regarding this matter to the undersigned.
| Very truly yours, | |
| /s/ Matthew McMurdo | |
| Matthew McMurdo, Esq. |
| cc: | M. Ann Courtney, President |
| BLVD Holdings, Inc. |
Matthew McMurdo, Esq.
New York
