August 13, 2004
Mail Stop 0305

Via U.S. Mail and facsimile (813) 223-7797
Michael Muzio
President, CFO and Director
Blue Moon Group, Inc.
513 North Franklin Street
Tampa, FL  33602

	Re:	Item 4, Form 8-K
		Filed August 11, 2004
File No.: 1-15455

Dear Mr. Muzio:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.

	Please understand that the purpose of our review process is to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other aspect
of our review.  Feel free to call us at the telephone numbers listed
at the end of this letter.

Exhibit 16:

1. Please file a letter from your former accountant indicating
whether or not they agree with your disclosures in the Form 8-K.  If
you are unable to obtain this letter from your former accountant,
please revise to disclose the reason(s).

Engagement of new accountant:

2. We note that you engaged a new accountant, Semple and Cooper LLP.
Please revise to disclose the date of the engagement as well as
whether during the two previous years and any subsequent period, you
consulted the newly engaged accountant regarding any of the items
detailed in Regulation S-K Item 304 (a)(2).  Please ensure that you
disclose any consultations up through the date of engagement.  If no
consultation was received, then please state so.

Please file your supplemental response and amendment via EDGAR in
response to these comments within 5 business days of the date of this
letter.  Please note that if you require longer than 5 business days
to respond, you should contact the staff immediately to request
additional time.

We welcome any questions you may have about our comments or on any
other aspect of our review.  You may contact me at 202-942-1785, or
in my absence, Robert Benton at 202-942-1811.

Sincerely,


								Theresa A. Messinese, CPA
Staff Accountant
Mr. Michael Muzio
Blue Moon Group, Inc.
August 13, 2004