VUMEE INC. 50 East Sample, Suite 301, Pompano Beach, FL, 33064 June 7, 2012 VIA EDGAR Securities and Exchange Commission 100 F. Street, NE Washington, D.C. 20549-7410 Attention: Mara L. Ransom Assistant Director Dear Sirs: Re: Vumee Inc. ("the Company") Form 8-K Filed May 25, 2012 File No. 000-53910 We refer to your letter of May 30, 2012 addressed to the Company with your comment on the Company's Form 8-K Current Report regarding the omission of pro forma financial statements. The transaction disclosed in the Form 8-K Current Report "Super 8-K" was accounted for as a reverse acquisition. Per the Q&A Memo regarding reverse acquisitions provided by the Division of Corporation Finance, "On the other hand, when a public shell with no operations and nominal net assets acquires an operating company with products and operations, the transaction would be accounted for as a recapitalization. In both these instances, the SEC staff has contended that APB No. 16 does not apply and pro forma financial information is not presented since the combination is not a business combination." For this reason, we believed that pro forma financial statements were not required. Yours truly, VUMEE INC. Per: /s/ Michael Spiegel --------------------------------- Michael Spiegel, President, CEO