August 9, 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:	Form 8-K filed August 4, 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.

1. Amend the report to include all of the information required by
Item 304 of Regulation S-K, including a statement on whether the
accountant`s report on the financial statements for either of the
past two years contained an adverse opinion or a disclaimer of
opinion or was qualified or modified as to uncertainty, audit scope
or accounting principles; and a description of the nature of each
such adverse opinion, disclaimer of opinion, modification or
qualification.  This would include disclosure of uncertainty
regarding the ability to continue as a going concern in the
accountant`s report.

2. The disclosure should also state whether during the registrant`s
two most recent fiscal years and any subsequent interim period
through the date of resignation, declination or dismissal there were
any disagreements with the former accountant on any matter of
accounting principles or practices, financial statement disclosure,
or auditing scope or procedure, which disagreement(s), if not
resolved to the satisfaction of the former accountant, would have
caused it to make reference to the subject matter of the
disagreement(s) in connection with its reports.  In the event of
disagreement(s) and/or




reportable event(s), provide the specific disclosures required by
Item 304(a)(1)(iv) of Regulation S-K.

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 9, 2004