THE O'NEAL LAW FIRM, P.C.
17100 East Shea Boulevard
Suite 400-D
Fountain Hills, Arizona 85268
(480) 812-5058 (Tel)
(480) 816-9241 (Fax)
H. Christopher Owings Securities and Exchange Commission 450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Fuego Entertainment, Inc.
Registration Statement on Form SB-2 (Amendment 4&5)
File No. 333-127612
Filed August 19, 2005
Dear Mr. Owings:
We are writing in response to your comment letter dated December 16, 2005 in
connection with the above-referenced filing. The numbered responses below
correspond to your numbered comments.
1. We have quantified and described specific significant costs and
expenses incurred and expected to be incurred during the next 12
months within the Plan of Operation section.
2. We have described the business of Tota Productions as a music and
video production company.
3. We have disclosed that we do not currently have any agreements or
projects whereby the company acts as an agent.
4. As the company has its own distribution, the company does not deem
this a material risk that need be disclosed in the Risk section.
5. We have revised this disclosure to disclose that minimum development
costs have been incurred to date, no revenues have been generated to
date and additional expected expenses will not exceed $10,000 per
project.
6. We have revised the document to reflect that the company has not
generated any revenues from the Havana Nights project.
7. We have disclosed the operating activities and financing activities
that earned the company the stated revenues, and the investing
activities that cost the company the stated amounts.
8. We believe we have already responded to this issue by stating that no
major expenses were incurred as the company simply acted on a work for
hire basis and received a fee for its services. We have defined the
term NHRA.
9. We have disclosed that the company has continued to generate revenues
with work for hire projects that consist of music and corporate video
production.
10. We have disclosed the loss for the period.
11. We have deleted this reference.
12. We have impaired the investment in Havana Nights per footnote 9 of the
notes to financial statements, and therefore have not responded to the
requested items in this comment.
13. We have revised the table to correctly reflect that Hugo Cancio
acquired 7,772,670 shares of the company's common stock on January 6,
2005 for $7,772.67. The totals have also been revised to reflect this
change. We have included the dates each purchaser acquired shares. The
amount of consideration paid by each shareholder is already set forth
in the table under the caption "PAID."
14. We have included a revised version of the undertakings.
Please do not hesitate to contact us if you have any further questions.
Very truly yours,
/s/William D. O'Neal
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William D. O'Neal
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