Simpson Thacher & Bartlett llp
American Lawyers
ICBC Tower, 35th Floor
3 Garden Road
Hong Kong
(852) 2514-7600
Facsimile: (852) 2869-7694
Direct Dial Number   E-Mail Address
+852 2514-7650
October 1, 2010
Mr. John Harrington, Staff Attorney
Ms. Celeste M. Murphy, Legal Branch Chief
Mr. Larry Spirgel, Assistant Director
Ms. Claire Delebar, Staff Accountant
Mr. Terry French, Accountant Branch Chief
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
     Re:   Focus Media Holding Limited
Annual Report on Form 20-F filed on June 29, 2010, amended on July 16, 2010 and
September 7, 2010 (file no. 00-51387)
Dear Mr. Harrington, Ms. Murphy, Mr. Spirgel, Ms. Delebar and Mr. French:
     We write on behalf of our client, Focus Media Holding Limited, a company organized under the laws of the Cayman Islands (the “Company” or “Bona Film”) with reference to the comment letter, dated September 22, 2010, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the above-referenced annual report on Form 20-F.
     The Company is requesting additional time to respond to the Staff’s comments. Due to the Mid-Autumn Festivals in China, which were a holiday from September through September  , 2010, the Company was not able to receive the Staff’s facsimile comment letter until September 27, 2010. Several days after that holida, starting today October 1 through October 7, 2010, there will also be holidays in China for National Day. As a result, neither the Company, their PRC legal counsel nor their independent auditors have been available to devote time to reviewing the
Leiming Chen Philip M.J. Culhane       Chris Lin       Sinead O’Shea         Jin Hyuk Park         Youngjin Sohn         Kathryn King Sudol
Resident Partners
Admitted in New York
New York Beijing Los Angeles London Palo Alto São Paulo Tokyo Washington, D.C.
simpson thacher & bartlett llp is a registered limited liability partnership established under the laws of the
state of new york. the personal liability of our partners is limited to the extent provided in such laws.
additional information is available upon request or at



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Simpson Thacher & Bartlett llp
Staff’s comments and will be unable to do so until after the holiday ends on October 7, 2010. Accordingly, the Company is initially requesting an additional two weeks of time after the original response due date of October 6 to fully review and respond to the Staff’s comments. The Staff’s understanding and accommodation in this request would be greatly appreciated.
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     If you have any question, please do not hesitate to contact me at +852 2514-7650, or my colleague Daniel Fertig at +852 2514-7660.
  Very truly yours,
  /s/ Daniel Fertig for Chris Lin    
  Chris Lin   
cc:   Kit Leong Low, Chief Financial Officer
Alex Deyi Yang, General Manager
Focus Media Holding Limited