Mail Stop 7010

      July 18, 2005

Via U.S. mail and facsimile

Mr. Joseph Mazin
President and Chief Executive Officer, The Flamemaster Corporation
11120 Sherman Way
Sun Valley, CA  91352

	RE:	Form 10-KSB for the fiscal year ended September 30, 2004
			File No. 0-2712

Dear Mr. Mazin:

		We have reviewed this filing and your response to our
letter dated April 19, 2005 and have the following comments.  If
you
disagree with a comment, we will consider your explanation as to
why
our comment is inapplicable or a revision is unnecessary.  Please
be
as detailed as necessary in your explanation.  In some of our
comments, we may ask you to provide us with supplemental
information
so we may better understand your disclosure.  After reviewing this
information, we may or may not raise additional 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 comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM 10-KSB FOR THE YEAR ENDED SEPTEMBER 30, 2004

Financial Statements

Statement of Income, page 15

1. We note your response to prior comment 3 and the proposed
changes
to your statement of income.  Given the description of royalty
expense provided in your response to prior comment 11 of your
letter
dated April 5, 2005, it appears that royalty expenses should
continue
to be included in income from operations before income taxes;
however, please present interest income, interest expense, and all
other non-operating items below the income from operations before
income taxes line item but before the provision for income taxes
line
item in an amendment to your Form 10-KSB for the year ended
September
30, 2004.

Note N - Long-Term Debt (Prior Years), page 25

2. We note your response to prior comment 14.  We remind you that
paragraph 41 of SFAS 144 states that a component of an entity may
be
a reportable segment or an operating segment, a reporting unit, a
subsidiary, or an asset group.  Your response to prior comment 10
states that Starbiz was a subsidiary.  Page 8 of your Form 10-KSB
also discusses the investment income recorded related to this
subsidiary.  Please report Starbiz in discontinued operations in
accordance with paragraphs 41 through 44 of SFAS 144 in an
amendment
to your Form 10-KSB for the year ended September 30, 2004.

FORM 10-QSB FOR THE PERIOD ENDED MARCH 31, 2005

Comment applicable to your overall filing

3. Please address the comments above in an amendment to your Form
10-
QSB for the period ended March 31, 2005.

*    *    *    *

		Please respond to these comments and file your amended
documents within 10 business days, or tell us when you will
provide
us with a response and amendments.  Please provide us with a
supplemental response letter that keys your responses to our
comments
and provides any requested supplemental information.  Detailed
letters greatly facilitate our review.  Please file your
supplemental
response on EDGAR as a correspondence file.  Please understand
that
we may have additional comments after reviewing your responses to
our
comments.

      If you have any questions regarding these comments, please
direct them to Marie Trimeloni, Staff Accountant, at (202) 551-
3734
or Nudrat Salik, Review Accountant at (202) 551-3692.

							Sincerely,



							Rufus Decker
							Accounting Branch Chief
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Mr. Joseph Mazin
July 18, 2005
Page 2 of 2




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE