Roaming Messenger, Inc.
                     50 Castilian Dr. Suite A, Santa Barbara
                                California 93117

                                                               August 10, 2005


VIA FACSIMILE (202-772-9203) AND EDGAR

United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Attention:  Scott Anderegg, Esq.

         Re:      Roaming Messenger, Inc.
                  Registration Statement on Form SB-2
                  File No. 333-124600

Ladies and Gentlemen:

      Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Act"), Roaming Messenger, Inc. (the
"Company") respectfully requests that the effective date of the registration
statement referred to above be accelerated so that it will become effective at
12.00 p.m., Eastern Time, on Thursday August 11, 2005, or as soon thereafter as
possible.

      We hereby acknowledge the following:

      o     that should the Commission or the staff, acting pursuant to
            delegated authority, declare the filing effective, it does not
            foreclose the Commission from taking any action with respect to the
            filing;

      o     the action of the Commission or the staff, acting pursuant to
            delegated authority, in declaring the filing effective, does not
            relieve the Company from its full responsibility for the adequacy
            and accuracy of the disclosure in the filing; and

      o     the Company may not assert staff comments and the declaration of
            effectiveness as a defense in any proceeding initiated by the
            Commission or any person under the federal securities laws of the
            United States.

                               ROAMING MESSENGER, INC.

                               By: /s/ Jon Lei
                                   --------------------------------------------
                                   Name: Jon Lei
                                   Title: President and Chief Executive Officer