Baixo Relocation Services, Inc. H. 190/5 Central Horte Aquem, Baixo, Goa, India 403601 August 19, 2014 U.S. Securities & Exchange Commission Division of Corporate Finance 450 Fifth Street, N.W. Washington, D.C. 20549-3561 Attention: Mara L. Ransom, Assistant Director Dear Sirs: Re: Amendment #1 to Registration Statement on Form S-1 filed August 5, 2014 (File No. 333-196663) In response to your letter dated August 12, 2014 relating to the above-noted registration statement, we provide an amended Form S-1 that addresses your comments and respond as follows: GENERAL 1. WE NOTE YOUR RESPONSE TO COMMENT 4 IN OUR LETTER DATED JULY 8, 2014 AND YOUR REVISIONS TO YOUR PROSPECTUS. PLEASE ALSO REVISE YOUR DISCLOSURE IN THE "PLAN OF DISTRIBUTION - DEPOSIT OF OFFERING PROCEEDS" SECTION, LOCATED NEAR THE BOTTOM OF PAGE 16, TO DISCUSS THE FACT THAT, DURING THE OFFERING, YOU WILL NOT PLACE FUNDS RECEIVED FROM INVESTORS IN ESCROW, AS WELL AS THE CONSEQUENCES OF SUCH FACT. We have added the following disclosure to the noted section: "We intend to open a separate, standard bank checking account to be used exclusively for the deposit of funds received from the sale of shares in this offering. Our management will have sole control over the withdrawal of funds from this account. We have not made arrangements to place the funds in an escrow account with a third party escrow agent due to the costs involved. As a result, investors are subject to the risk that creditors could attach these funds during the offering process, as well as the risk that investment amounts could be lost due to the fact that they are held in an operating account." INFORMATION WITH RESPECT TO THE REGISTRANT, PAGE 17 2. WE NOTE YOUR RESPONSES TO COMMENTS 11 AND 12 IN OUR LETTER DATED JULY 8, 2014. PLEASE PROVIDE US WITH COPIES OF THE MATERIALS CITED IN YOUR REVISED DISCLOSURES THAT SUPPORT YOUR DISCUSSION. FOR EXAMPLE, YOU CITE AS
AUTHORITY FOR YOUR DISCLOSURES CARTUS TRENDS IN GLOBAL RELOCATION AND BROOKFIELD GLOBAL RELOCATION SERVICES. PLEASE MARK YOUR FINISHED SUPPORT OR PROVIDE PAGE REFERENCES IN YOUR RESPONSE TO THE SECTIONS YOU RELY UPON FOR EACH SPECIFIC STATEMENT. TO THE EXTENT YOU ARE UNABLE TO PROVIDE SUPPORT, PLEASE DELETE THE DISCLOSURE. We have updated the statements concerning the demand for relocation services to reflect that the 2014 Cartus Trends in Global Relocation report is now publicly available. The statements in the section of our registration statement titled "Demand for Relocation Services" are based on two sources: 1. the 2013 Cartus Trends in Global Relocation survey report entitled "Global Mobility Policies & Practices" (the "Cartus Report") that can be accessed online via the following link: http://guidance.cartusrelocation.com/research-and-trends-2014-global- mobility-policies-and-practices-survey.html; and 2. the 2012 Brookfield Global Relocation Services report entitled "Global Relocation Trends: 2012 Survey Report" (the "Brookfield Report") that can be accessed online via the following link: http://www.ikgundemi.com/uploads/6/7/8/0/6780997/2012_grts.pdf Each specific statement in this section can be found on the following page of the report: a) India ranks sixth in countries with the most relocation activity (Cartus Report, page 7); b) Along with China and Brazil, India was named among the most challenging relocation destinations for companies and employees (Cartus Report, page 7); c) India placed second after China in terms of relocation failure (Brookfield Report, page 18 and 65); and d) India was the top developing country destination for employee relocations after China and Brazil (Brookfield Report, page 11). In the section entitled "Services", we cite the now available Institute of Chartered Accountants in India's 2012-2013 annual report as the basis for the statement that there were approximately 217,000 chartered accountant members in the country as of April 1, 2013. That figure is located on page 168 of the report that can be accessed online via the following link: http://www.icai.org/new_post.html?post_id=1260&c_id=200 2
Because this is an RAR file that may be difficult to open, we have included the scanned page of the report as correspondence with this filing. EXHIBITS 3. WE NOTE YOUR RESPONSE TO COMMENT 16 IN OUR LETTER DATED JULY 8, 2014 AND YOUR FILING OF THE SUBSCRIPTION AGREEMENT. HOWEVER, THE PRICE PER SHARE IN YOUR SUBSCRIPTION AGREEMENT IS $0.01, WHILE THE PRICE DISCLOSED IN YOUR PROSPECTUS IS $0.015. PLEASE REVISE OR ADVICE. We have filed an amended form of subscription agreement as an exhibit that now includes the correct price per share. Yours truly, /s/ Rosy Rodrigues ------------------------------------- Rosy Rodrigues, President Baixo Relocation Services, Inc. 3