AS FILED WITH THE SECURITY AND EXCHANGE COMMISSION ON FEBRUARY 25, 2005
                                                           REGISTRATION NO. 333-

                                  UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                    FORM SB-2
             REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933

                       SPONGETECH DELIVERY SYSTEMS, INC. 
                 ----------------------------------------------
                 (Name of small business issuer in its charter)

          Delaware                          2840                  54-2077231
------------------------------ ----------------------------  -------------------
  (State or jurisdiction of    (Primary Standard Industrial    (I.R.S. Employer 
incorporation or organization)  Classification Code Number)  Identification No.)


  The Empire State Building, 350 Fifth Avenue, Suite 2204, New York, New York
                              10118 (212) 594-4175
  ---------------------------------------------------------------------------
          (Address and telephone number of principal executive offices)

              Michael L. Metter, Spongetech Delivery Systems, Inc.
       The Empire State Building, 350 Fifth Avenue, Suite 2204, New York,
                         New York 10118 (212) 594-4175
       ------------------------------------------------------------------
            (Name, address and telephone number of agent for service)

                                   COPIES TO:

                            Richard A. Friedman, Esq.
                       Sichenzia Ross Friedman Ference LLP
                           1065 Avenue of the Americas
                            New York, New York 10018
                                 (212) 930-9700

                  APPROXIMATE DATE OF PROPOSED SALE TO PUBLIC:
   As soon as practicable after this registration statement becomes effective.

If this Form is filed to register additional securities for an offering pursuant
to Rule 462(b) under the Securities Act, please check the following box and list
the  Securities  Act  registration  statement  number of the  earlier  effective
registration statement for the same offering. |_|

If this Form is a  post-effective  amendment filed pursuant to Rule 462(c) under
the  Securities  Act,  check  the  following  box and  list the  Securities  Act
registration  statement number of the earlier effective  registration  statement
for the same offering. |_|

If this Form is a  post-effective  amendment filed pursuant to Rule 462(d) under
the  Securities  Act,  check  the  following  box and  list the  Securities  Act
registration  statement number of the earlier effective  registration  statement
for the same offering. |_|

If delivery  of the  prospectus  is  expected  to be made  pursuant to Rule 434,
please check the following box. |_|

                       (COVER CONTINUES ON FOLLOWING PAGE)





                                                  CALCULATION OF REGISTRATION FEE
===================================================================================================================================
                                                                   PROPOSED MAXIMUM       PROPOSED MAXIMUM
    TITLE OF EACH CLASS OF SECURITIES          AMOUNT TO BE       OFFERING PRICE PER     AGGREGATE OFFERING        AMOUNT OF
            TO BE REGISTERED                    REGISTERED           SECURITY (1)              PRICE            REGISTRATION FEE
------------------------------------------ --------------------- ---------------------- --------------------- ---------------------
                                                                                                            
Units consisting of one share of Common          
Stock, par value $.001 per share
(:Common Stock") and one Redeemable
Class A Warrant ("Class A Warrant')
entitling the holder to purchase one
share of Common Stock                            8,000,000               $0.25               $2,000,000             $235.40
------------------------------------------ --------------------- ---------------------- --------------------- ---------------------
Common Stock includable in Class A               
Warrants                                         8,000,000                 (2)                   (2)                  (2)
------------------------------------------ --------------------- ---------------------- --------------------- ---------------------
Common Stock issuable upon exercise of                                                                              $470.80
Class A Warrants                                 8,000,000               $0.50                4,000,000
------------------------------------------ --------------------- ---------------------- --------------------- ---------------------
Common Stock, $.001 par value per share         17,259,344               $0.25                4,314,836             $507.86
------------------------------------------ --------------------- ---------------------- --------------------- ---------------------
 Total Registration Fee                                                                                           $1,214.06
===================================================================================================================================


(1)   Estimated solely for purposes of calculating the registration fee in
      accordance with Rule 457(e) under the Securities Act of 1933.

(2)   In accordance with Rule 457, no separate registration fee is required.


         The registrant hereby amends this  Registration  Statement on such date
or dates as may be necessary to delay its  effective  date until the  registrant
shall file a further amendment which specifically  states that this Registration
Statement shall  thereafter  become effective in accordance with Section 8(a) of
the Securities  Act of 1933 or until this  Registration  Statement  shall become
effective on such date as the  Commission,  acting pursuant to said Section 8(a)
may determine.



THE  INFORMATION IN THIS  PROSPECTUS IS NOT COMPLETE AND MAY BE CHANGED.  WE MAY
NOT SELL  THESE  SECURITIES  UNTIL THE  REGISTRATION  STATEMENT  FILED  WITH THE
SECURITIES AND EXCHANGE COMMISSION IS EFFECTIVE. THIS PROSPECTUS IS NOT AN OFFER
TO SELL THESE  SECURITIES AND IS NOT SOLICITING AN OFFER TO BUY THESE SECURITIES
IN ANY STATE WHERE THE OFFER OR SALE IS NOT PERMITTED.

     PRELIMINARY PROSPECTUS, SUBJECT TO COMPLETION, DATED FEBRUARY 25, 2005

                        SPONGETECH DELIVERY SYSTEMS, INC.


                       UP TO 8,000,000 UNITS CONSISTING OF
                            ONE SHARE OF COMMON STOCK
                                       AND
                         ONE REDEEMABLE CLASS A WARRANT

                                       AND

                              17,259,344 SHARES OF
                                  COMMON STOCK

 
            We are  offering a minimum of  2,000,000  units,  up to a maximum of
8,000,000  units,  on a  "best-efforts"  basis, at an offering price of $.25 per
unit. Each unit consists of one share of common stock,  $.001 par value, and one
redeemable class A warrant. The units are being offered for a period of 60 days,
subject to an extension of up to an  additional  30-day  period.  If the minimum
amount of the offering is not sold within the offering period,  investors' funds
will be promptly  returned without interest or deduction.  Pending release,  all
proceeds of the  offering  will be deposited in a  non-interest  bearing  escrow
account with Continental Stock Transfer & Trust Company, Inc.

            We intend to sell the  units  through  our  officers,  directors  or
employees,   but  we  reserve  the  right  to  make  sales  through   registered
broker-dealers.  If we make such sales  through  broker-dealers,  we reserve the
right to pay commissions to them of up to 10% of the sales price and pay them an
additional non-accountable expense allowance of up to 3% of the sales price.

            This prospectus also relates to the resale of 17,259,636  additional
shares,  including an aggregate of 11,282,375 shares to be offered by Michael L.
Metter (1,665,000 shares),  Steven Moskowitz (2,803,333 shares),  Thomas Monahan
(100,000  shares),  Frank  Lazauskas  (3,330,000  shares)  and The Rubin  Family
Irrevocable  Stock Trust (3,391,868  shares),  all of whom are affiliates of us.
There is currently no public market for the Spongetech Delivery Systems,  Inc.'s
securities.  Until such time as a market price for our common stock is quoted on
the OTC Bulletin Board, all of the selling  shareholders  will sell their shares
at a price of $0.25 per share. Thereafter,  they may sell their shares in public
or private transactions,  at prevailing market prices or at privately negotiated
prices.  We will not receive any proceeds  from the sale of the shares of common
stock by the selling shareholders.

            YOUR INVESTMENT IN OUR UNITS INVOLVES A HIGH DEGREE OF RISK.  BEFORE
INVESTING IN OUR COMMON STOCK, YOU SHOULD CONSIDER CAREFULLY THE RISKS DESCRIBED
UNDER "RISK FACTORS" BEGINNING ON PAGE 6.

         NEITHER THE SECURITIES AND EXCHANGE COMMISSION NOR ANY STATE SECURITIES
COMMISSION HAS APPROVED OR DISAPPROVED OF THESE SECURITIES OR DETERMINED IF THIS
PROSPECTUS  IS TRUTHFUL OR  COMPLETE.  ANY  REPRESENTATION  TO THE CONTRARY IS A
CRIMINAL OFFENSE.

 
                THE DATE OF THIS PROSPECTUS IS ___________, 2005



                                TABLE OF CONTENTS

                                                                            Page
                                                                            ----

Prospectus Summary                                                            1
Selected Financial Data                                                       2
Risk Factors                                                                  6
Use of Proceeds                                                              11
Market for Common Equity and Related Stockholder Matters                     11
Dividend Policy                                                              12
Dilution                                                                     12
Capitalization                                                               12
Management's Discussion and Analysis of Financial Condition and Results 
   of Operations                                                             13
Business                                                                     16
Legal Proceedings                                                            19
Management                                                                   19
Executive Compensation                                                       20
Certain Relationships and Related Transactions                               21
Security Ownership of Certain Beneficial Owners and Management               23
Description of Securities                                                    24
Selling Stockholders                                                         26
Share Eligible for Future Sale                                               28
Plan of Distribution                                                         28
Indemnification                                                              31
Legal Matters                                                                31
Experts                                                                      31
Additional Information                                                       32
 



                               PROSPECTUS SUMMARY

          The following summary  highlights  selected  information  contained in
this  prospectus.  This summary does not contain all the  information you should
consider  before  investing  in the  securities.  Before  making  an  investment
decision,  you should read the entire prospectus carefully,  including the "RISK
FACTORS"  section,  the  financial  statements  and the  notes to the  financial
statements.   As  used  throughout  this  prospectus,   the  terms  "Spongetech"
"Spongetech  Delivery  Systems," the  "Company,"  "we," "us," and "our" refer to
Spongetech Delivery Systems, Inc.

                        SPONGETECH DELIVERY SYSTEMS, INC.

         We  design,  produce,  market  and  distribute  cleaning  products  for
vehicular  use  utilizing  patented  technology  relating to sponges  containing
hydrophilic,  which  are  liquid  absorbing,  foam  polyurethane  matrices.  Our
products can be pre-loaded  with  detergents and waxes which are absorbed in the
core of the sponge then gradually released during use. We have also designed and
started to test market,  but have not yet produced or sold,  products  using the
same  hydrophilic  technology  for bath and home use.  We license  the rights to
manufacture and sell our products from H.H. Brown Shoe Technologies, Inc. (d/b/a
Dicon  Technologies),  the  holder  of  the  relevant  patents  relating  to the
hydrophilic  sponges. We license the rights to manufacture and sell our products
from H.H. Brown Shoe Technologies,  Inc. (d/b/a Dicon Technologies),  the holder
of the relevant patents relating to the hydrophilic sponges.

         Our  principal  executive  offices  are  located  at The  Empire  State
Building,  350 Fifth Avenue, Suite 2204, New York, New York 10118. Our telephone
number is (212) 594-4175.

                              OUR CORPORATE HISTORY

         We were formed on June 18, 1999, under the name Romantic  Scents,  Inc.
On June 12, 2001,  Romantic  Scents,  Inc.  changed its name to RSI Enterprises,
Inc., and, on October 2, 2002, changed its name to Spongetech International Ltd.
On July 15,  2002,  we  entered  into a stock  purchase  agreement  with  Nexgen
Acquisitions  VIII, Inc. pursuant to which our sole stockholder,  RM Enterprises
International, Inc. received 12,000,000 shares of Nexgen Acquisitions VIII, Inc.
and thereby became its majority  stockholder.  The transaction was accounted for
as a reverse  acquisition  using the purchase  method of accounting,  whereby RM
Enterprises  International,  Inc., our sole shareholder,  retained approximately
63% of the  outstanding  common stock.  Thereafter,  on October 9, 2002,  Nexgen
Acquisitions VIII, Inc. changed its name to Spongetech Delivery Systems, Inc. On
December 16, 2002,  we changed our  domicile to  Delaware.  Spongetech  Delivery
Systems,  Inc. (formerly Nexgen Acquisitions VIII, Inc.) merged with and into us
so that we became the surviving company.  Immediately  subsequent to the merger,
we changed our name to Spongetech Delivery Systems, Inc.

         We have incurred  losses since  inception and we expect to incur losses
for the foreseeable  future. For the six-months ended November 30, 2004, and the
fiscal  years ended May 31,  2004 and May 31,  2003,  we incurred  net losses of
$17,172, $2,056,526 and $265,517,  respectively.  As of November 30, 2004 we had
an  accumulated  deficit  of  $2,692,210  and a working  capital  deficiency  of
$1,928,152.  These  conditions  raise  substantial  doubt  about our  ability to
continue as a going concern.



                                       1


                                  THE OFFERING



                                        
Common stock outstanding 
  before the offering....................  33,952,636shares.

Securities offered by Spongetech.........  Up to 8,000,000  units,  each  consisting  of
                                           one share of common stock and one  redeemable
                                           class A  warrant.  The  common  stock and the
                                           redeemable   class  A  warrant   will  become
                                           separately  tradable  after 90 days  from the
                                           initial  closing of this offering,  or sooner
                                           in our  discretion.  We  will  issue  a press
                                           release if we  determine  to allow the common
                                           stock  and  class A  redeemable  warrants  to
                                           become   separately   tradable  prior  to  90
                                           days.
Common stock offered by selling 
  stockholders...........................  17,259,344 shares

Common stock to be outstanding after 
  the offering

Minimum Offering.........................  Upon  completion  of  the  minimum   offering
                                           there  will be  35,952,636  shares  of common
                                           stock  and  2,000,000   redeemable   class  A
                                           warrants outstanding.

Maximum Offering.........................  Upon  completion  of  the  maximum   offering
                                           there  will be  41,952,636  shares  of common
                                           stock  and  8,000,000   redeemable   class  A
                                           warrants outstanding.
Redeemable Class A Warrants
Exercise Terms...........................  Each redeemable  class A warrant entitles the
                                           registered  holder  thereof to  purchase,  at
                                           any time  from the date the  warrants  become
                                           separately   tradable,   until  ______,  2010
                                           (five  years  after  the  date  hereof),  one
                                           share of common  stock at an  exercise  price
                                           of $0.50 per share, subject to adjustment.

Redemption...............................  The   redeemable   class   A   warrants   are
                                           redeemable  by us at a  redemption  price  of
                                           $0.001  per  warrant,  upon at least 30 days'
                                           prior   written    notice,    commencing   on
                                           _________,  2005 (six  months  after the date
                                           hereof),  if the average of the closing  high
                                           bid prices of the common stock  exceeds $1.00
                                           for five  consecutive  trading days ending on
                                           the  third  day  prior  to the  date on which
                                           notice is given.

Risk Factors.............................  See "Risk  Factors,"  beginning on page 3 for
                                           a description  of certain  factors you should
                                           consider  before  making an investment in our
                                           common stock.

Use of proceeds..........................  We will  use the  proceeds  from  the sale of
                                           all or any  portion  of the  8,000,000  units
                                           offered  by  us  for   working   capital  and
                                           general  corporate  purposes.   We  will  not
                                           receive any proceeds  from the sale of any of
                                           the   17,259,344   shares  of  common   stock
                                           subject    to   resale    by   the    selling
                                           stockholders under this prospectus


                                       2




                                        
Forward-Looking Statements...............  This  prospectus   contains   forward-looking
                                           statements that address,  among other things,
                                           our   strategy  to  develop   our   business,
                                           projected  capital  expenditures,  liquidity,
                                           and our  development  of  additional  revenue
                                           sources.  The forward-looking  statements are
                                           based  on our  current  expectations  and are
                                           subject   to   risks,    uncertainties    and
                                           assumptions.  We base  these  forward-looking
                                           statements    on    information     currently
                                           available to us, and we assume no  obligation
                                           to  update  them.   Our  actual  results  may
                                           differ    materially    from   the    results
                                           anticipated    in    these    forward-looking
                                           statements, due to various factors.


                             SELECTED FINANCIAL DATA

         The  selected  statement  of  operations  data for the two fiscal years
ended May 31, 2004 and 2003 and the six months ended November 30, 2004 and 2003,
and the following  selected balance sheet data as of May 31, 2004 and August 31,
2004 are derived from our audited  financial  statements  included  elsewhere in
this  prospectus  and have been  audited by  Drakeford  &  Drakeford,  LLC.  The
following  selected  financial  data  have  been  prepared  in  accordance  with
generally  accepted  accounting  principles.  The financial data set forth below
should be read in  conjunction  with  "Management's  Discussion  and Analysis of
Financial Condition and Results of Operations" and the financial  statements and
notes thereto appearing elsewhere in the prospectus.

         The  selected  statement  of  operations  data for the two fiscal years
ended May 31, 2004 and 2003 and the six months ended November 30, 2004 and 2003,
(unaudited) and the following selected balance sheet data as of May 31, 2004 are
derived from our financial statements included elsewhere in this prospectus. The
following  selected  financial  data  have  been  prepared  in  accordance  with
generally  accepted  accounting  principles.  The financial data set forth below
should be read in  conjunction  with  "Management's  Discussion  and Analysis of
Financial Condition and Results of Operations" and the financial  statements and
notes thereto appearing elsewhere in the prospectus.

                        SPONGETECH DELIVERY SYSTEMS, INC.
                            STATEMENTS OF OPERATIONS

                                    For the                  For the
                               Six Months Ended            year ended
                                 November 30,                 May 31,
                           ------------------------    --------------------
                              2004         2003          2004         2003
                              ----         ----          ----        -----
                          (unaudited)  (unaudited)

Sales                      $      0      $  2,123       $  1,858    $ 342,019

Cost of goods sold                0         5,136          1,600      299,617
                           ----------    ---------      --------    ----------
Gross profit (loss)               0        (3,013)           258       42,402
                           ----------    ---------      --------    ----------
Operating expenses
  Selling                         0        25,052         39,535       55,261
  General and
   Administrative
   expenses                  15,030        25,462      2,007,953      241,428
  Depreciation expense        2,142         2,750          4,284       10,830
                            -------       --------       --------   ----------

Total operating expenses     17,172        53,264      2,051,772      307,519
                            --------      --------      --------    ---------
Loss before provision
 for income taxes           (17,172)      (56,277)    (2,051,514)    (265,117)

Other income and expenses
  Interest expense                              0          5,012          400
                            --------        -----          ------     -------
Total income and
  expense                                       0          5,012          400

Net loss                   ($17,172)    $ (56,277)   $(2,056,526)   $(265,517)
                             ========    ========       =========    ========
Basic and diluted (loss)
   per common stock

Net loss per share -
   basic and diluted         $ (.01)       $ (.01)       $  (.01)    $   (.01)
                          =========     =========        ========   =========

Weighted average common
   shares outstanding    18,985,000    18,985,000     18,985,000   18,985,000
                         ==========   ===========      ==========  ==========

                                       3


                        SPONGETECH DELIVERY SYSTEMS, INC.
                            STATEMENTS OF CASH FLOWS

                                          For the Six
                                          Months Ended         For the
                                          November 30,    Year Ended May 31,
                                         -------------    ------------------
                                        2004      2003     2004        2003
                                    (unaudited)(unaudited)

Operating Activities:
 Net loss                            $(17,172) $(56,277) $(2,056,526) $(265,517)
 Adjustments to reconcile net loss to
 net cash provided by (used in)
 operating activities
 Value of contributed officer
   compensation                             0         0            0     39,000
 Bad debts                                  0         0            0     13,909
 Depreciation                           2,142     2,750        4,284     10,830
 Common stock subscribed in release
   of company debt                          0         0      526,814          0

Changes in operating assets and
   liabilities
   Accounts receivable                      0         0       15,003     (1,395)
   Inventories                              0       852          852     48,061
   Prepaid expense and other
     current assets                         0         0            0        118
   Accounts payable and accrued
     expenses                               0    (1,836)    (121,404)    94,383
   Accrued compensation                15,000         0    1,789,500          0
   Income taxes payable                     0         0            0        400
   Due to related parties                   0    15,871     (159,578)    30,949
                                    ---------    -------    --------   --------

Net cash provided by (used in)
 operating activities                     (30)  (38,640)      (1,055)   (29,262)
                                    ---------    --------   --------  ---------
Investing Activities:
 Acquisition of property and
  equipment                                 0      (728)           0     (7,700)
                                    ---------    --------   --------    --------
Net cash used in investing
 activities                                 0      (728)           0     (7,700)
                                    ---------    -------    --------    --------

Financing Activities:
Proceeds from factor, net                   0    13,608            0    (13,608)
Proceeds of note payable - related
party                                       0    25,000            0     51,500
                                   ---------   ---------    --------   ---------
Net cash provided by
financing activities                       0     38,608            0     37,892
                                   ---------   ---------    --------   ---------

Net increase (decrease) in cash         (30)       (760)      (1,055)       930

Cash - beginning                         50        1,105       1,105        175
                                    --------     -------    -------      ------
 Cash - end                         $    20     $    345      $   50    $ 1,105
                                    ========     =======     =======      ======


                                       4


                                 Unaudited    Unaudited
                                November 30, November 30,   May 31,     May 31,
                                    2004        2003         2004        2003


Balance Sheet Data
Total Assets                     $ 31,153      $37,205      $33,325     $56,710


Stockholders Deficiency       $(1,897,463)   $(406,856) $(1,880,291)  $(350,579)




                                       5


                                  RISK FACTORS
 
         Our business involves a high degree of risk. Potential investors should
carefully  consider the risks and  uncertainties  described  below and the other
information in this prospectus  before  deciding  whether to invest in shares of
our common stock. If any of the following  risks actually  occur,  our business,
financial condition, and results of operations could be materially and adversely
affected.  This could  cause the trading  price of our common  stock to decline,
with the loss of part or all of an investment in the common stock.

RISKS RELATING TO OUR BUSINESS

WE HAVE A HISTORY OF LOSSES SINCE OUR  INCEPTION  AND EXPECT TO INCUR LOSSES FOR
THE FORESEEABLE FUTURE.

         We incurred net losses of $17,172 and $2,056,526  during the six months
ended November 30, 2004 and for the year ended May 31, 2004, respectively. As of
November 30, 2004 we have a working  capital  deficit of $1,928,152.  Because of
these conditions, we will require additional working capital to develop business
operations.  We have not achieved  profitability  and we can give no  assurances
that we will achieve  profitability  within the foreseeable  future,  as we fund
operating  and capital  expenditures,  in such areas as sales and  marketing and
research and  development.  We cannot assure investors that we will ever achieve
or sustain  profitability  or that our operating losses will not increase in the
future,  which  could  cause  investors  to lose  the  entire  amount  of  their
investment.

WE HAVE A LIMITED  OPERATING  HISTORY UPON WHICH AN  EVALUATION OF OUR PROSPECTS
CAN BE MADE. FOR THAT REASON, IT WOULD BE DIFFICULT FOR A POTENTIAL  INVESTOR TO
JUDGE OUR PROSPECTS FOR SUCCESS.

            We were organized in July 1999 and have had limited operations since
our inception from which to evaluate our business and prospects. There can be no
assurance that our future proposed  operations will be implemented  successfully
or  that we  will  ever  have  profits.  Our  limited  financial  resources  are
significantly less than those of other companies, which can develop alternatives
to our current and pending product lines in the U.S. If we are unable to sustain
our  operations,  you may lose  your  entire  investment.  We face all the risks
inherent in a new business, including the expenses, difficulties,  complications
and delays  frequently  encountered in connection  with  conducting  operations,
including capital  requirements and management's  potential  underestimation  of
initial and ongoing  costs.  In  evaluating  our business and  prospects,  these
difficulties should be considered.

WE NEED  SIGNIFICANT  INFUSIONS  OF  ADDITIONAL  CAPITAL,  WHICH  MAY  RESULT IN
DILUTION TO YOUR OWNERSHIP AND VOTING RIGHTS IN US.

           Based upon our current cash reserves and  forecasted  operations,  we
believe  that we will need to obtain at least  $500,000  in  outside  funding to
implement  our  plan of  operation  over the next  twelve  months.  Our need for
additional capital to finance our business strategy, operations, and growth will
be greater should, among other things,  revenue or expense estimates prove to be
incorrect. If we fail to arrange for sufficient capital in the future, we may be
required  to reduce  the scope of our  business  activities  until we can obtain
adequate  financing.  We may not be  able  to  obtain  additional  financing  in
sufficient  amounts or on acceptable  terms when needed,  which could  adversely
affect our  operating  results  and  prospects.  Debt  financing  must be repaid
regardless of whether or not we generate profits or cash flows from our business
activities. Equity financing may result in dilution to existing stockholders and
may involve  securities  that have rights,  preferences,  or privileges that are
senior to our common stock.

OUR INDEPENDENT  AUDITORS HAVE EXPRESSED  SUBSTANTIAL DOUBT ABOUT OUR ABILITY TO
CONTINUE  AS A GOING  CONCERN,  WHICH MAY  HINDER OUR  ABILITY TO OBTAIN  FUTURE
FINANCING.

         For the year ended May 31, 2004, our  independent  auditors stated that
our financial  statements for the year ended May 31, 2004 were prepared assuming
that we would  continue as a going  concern.  Our ability to continue as a going
concern is an issue raised as a result of recurring  losses from  operations and
cash flow deficiencies from our inception. We continue to experience net losses.
Our ability to continue as a going concern is subject to our ability to generate
a profit  and/or  obtain  necessary  funding  from  outside  sources,  including
obtaining  additional funding from the sale of our securities,  increasing sales
or  obtaining  loans  and  grants  from  various  financial  institutions  where
possible.  Our  continued  net losses and  stockholders'  deficit  increases the
difficulty  in  meeting  such  goals and there  can be no  assurances  that such
methods will prove successful.


                                       6


IF WE ARE NOT ABLE TO MANAGE GROWTH OF OUR BUSINESS, OUR FINANCIAL CONDITION AND
RESULTS OF OPERATIONS WILL BE NEGATIVELY AFFECTED.

            We  anticipate  a period of  significant  growth.  This growth could
cause  significant  strain on our managerial,  operational,  financial and other
resources.  Success in managing this expansion and growth will depend,  in part,
upon the  ability  of our  management  to  effectively  manage the growth of our
business.  Any  failure  to manage the  proposed  growth  and  expansion  of our
business  could have a material  adverse  effect on our financial  condition and
results of operations.

OUR FUTURE  SUCCESS IS  DEPENDENT,  IN PART,  ON THE  PERFORMANCE  AND CONTINUED
SERVICE OF OUR OFFICERS.

            Our  performance  and future  operating  results  are  substantially
dependent on the continued  service and  performance  of Michael L. Metter,  our
President  and  Steven  Moskowitz,  our  Secretary.  If  their  services  become
unavailable,  our business and prospects would be adversely affected.  We do not
currently maintain "key employee" insurance for any of our executive officers or
other key  employees  and do not intent to obtain this type of  insurance  until
such time as we have  positive cash flow and are  profitable.  The loss of their
services  could  have a  material  adverse  effect on our  financial  condition,
operating results, and on the public market for our common stock.

OUR LICENSE IS LIMITED TO PRODUCTS FOR USE IN THE  CLEANING OF VEHICLES;  AND WE
MAY NOT BE ABLE TO EXPAND OUR BUSINESS INTO THE SALE OF OTHER PRODUCTS USING THE
SAME TECHNOLOGY.

         We rely on our license  agreement with Dicon for the development of our
products.  Our  principal  product and our products  that are under  development
utilize the hydrophilic sponge technology that we license from Dicon. We rely on
Dicon to  protect  and  enforce  key  patents  held by  Dicon,  relating  to the
hydrophilic  technology.  Dicon's  patent  expires in 2017. In the past, we have
defaulted on the license by not meeting our minimum supply  requirements.  If we
default   again,   Dicon  may  terminate  the  agreement  or  make  the  license
non-exclusive.  If we lose our license,  we may not be able to make  alternative
arrangements on terms  acceptable to us, or at all. We do not currently have any
alternative  plans for which to purchase  hydrophilic  sponges.  Any loss of our
license could materially adversely affect our business,  financial condition and
results of operations.

OUR  EXCLUSIVE  LICENSE IS LIMITED TO ONE  FUNCTION.  IF WE ARE UNABLE TO EXPAND
THIS LICENSE TO OTHER AREAS, OUR GROWTH WILL BE SIGNIFICANTLY LIMITED.

            Our license  agreement with Dicon is limited to hydrophilic  sponges
used to clean and polish land, sea and air transportation vehicles. Our business
plan calls for us to expand our product line using hydrophilic  sponges into the
areas of personal  hygiene and  household  cleaning.  Although  Dicon has orally
indicated that it will agree to expand our license to cover personal hygiene and
household cleaning products and has produced samples of both products for us, we
have no  written  assurances  that Dicon will  expand our  exclusive  license to
include  additional  product lines.  If Dicon refuses to expand our license,  we
will be unable to expand into new areas and our growth will be limited.

WE DEPEND ON PRODUCTS MADE USING ONE  TECHNOLOGY;  AND PRODUCTS USING  DIFFERENT
TECHNOLOGIES MAY ATTRACT CUSTOMERS JEOPARDIZING OUR BUSINESS PROSPECTS.

         Our cleaning products depend on the use of licensed technology relating
to sponges incorporating a hydrophilic (liquid absorbing) polyurethane matrix. A
number of factors could limit our sales of these products,  or the profitability
of such sales,  including  competitive efforts by other manufacturers of similar
products,  shifts in consumer  preferences or the introduction and acceptance of
alternative  product  offerings.  We have not  developed  products  using  other
technologies;  and,  thus, if our existing  products or others based on the same
technology fail in the marketplace, our business would fail.

OUR LICENSOR  MAY NOT BE  SUCCESSFUL  IN  DEFENDING  THE PATENTS ON OUR LICENSED
TECHNOLOGY AGAINST  INFRINGEMENT;  AND, AS A RESULT, WE MAY BE UNABLE TO COMPETE
AGAINST COMPANIES SELLING PRODUCTS USING THE SAME TECHNOLOGY AS WE DO.


                                       7


            In the event a competitor  infringes  upon our licensed  technology,
our licensor may be unable to successfully assert patent infringement claims. In
that event,  we may encounter  direct  competition  using the same technology on
which our  products  are based  and we may be  unable to  compete.  If we cannot
compete with competitive  products,  our business will fail. In addition, if any
third party claims that our licensed products are infringing their  intellectual
property rights, any resulting litigation could be costly and time consuming and
would divert the attention of management  and key personnel  from other business
issues. We also may be subject to significant damages or injunctions  preventing
us from  selling  or  using  some  aspect  of our  products  in the  event  of a
successful  patent or other  intellectual  property  infringement  claim. Any of
these adverse  consequences could have a material adverse effect on our business
and profitability.

THROUGHOUT OUR SALES HISTORY, WE HAVE DEPENDED ON ONE CUSTOMER FOR ALMOST ALL OF
OUR SALES. IF THAT CUSTOMER DOES NOT GIVE US REPEAT ORDERS,  WE WILL NOT BE ABLE
TO CONTINUE IN BUSINESS.

         In  the  past,  we  have  relied  on  one  customer,  TurtleWax,  for a
significant  percentage  of our  orders.  We are  exploring  ways to market  our
automobile cleanser and wax product,  children's bath and home cleaning products
through other marketing channels.  To date, these channels have generated little
revenues for our automobile  product and no revenues for our other products.  We
can offer no assurance  that these  efforts  will ever prove to be  commercially
viable for us. If we are unable to expand our client and sales base, we may have
no existing business or prospects for new business and our business would fail.

WE DEPEND ON ONE MANUFACTURER FOR ALL OUR PRODUCTS;  AND IF THAT MANUFACTURER IS
UNWILLING OR UNABLE TO PRODUCE OUR ORDERS IN THE QUANTITIES  REQUIRED AND AT THE
PRICE AND  QUALITY  WE  REQUIRE  FOR  SALES,  WE WILL BE UNABLE TO  CONTINUE  IN
BUSINESS.

         Our licensor is also our manufacturer.  Our reliance on a sole supplier
involves  several risks,  including our potential  inability to obtain  adequate
supplies  and reduced  control over  pricing and timely  delivery.  Although the
timeliness,  quality  and  pricing  of  deliveries  from our  licensor  has been
acceptable to date there can be no assurance  that supplies will be available on
an acceptable  basis or that delays in obtaining new suppliers  will not have an
adverse effect on us. If we lose this manufacturer there is no guarantee that we
will be able to make alternate  arrangements  that will be acceptable to us. Our
inability  to  obtain  adequate  supplies  of  hydrophilic  sponges,  chemicals,
packaging  materials,  or finished  products  would  prevent us from  fulfilling
orders and would result in the decline or failure of our business.

THE MARKETPLACE  MAY BE INDIFFERENT TO OUR PRODUCTS;  IN WHICH CASE OUR BUSINESS
WILL FAIL.

         Our  hydrophilic  sponges,  and  products  based  on them,  feature  an
internal structure which holds detergents and waxes which are released only when
squeezed. However, potential users may be satisfied with the cleaners, waxes and
applicators  they are  presently  using.  Thus,  we may expend our financial and
personnel  resources on design,  marketing and  advertising  without  generating
concomitant  revenues.  If we cannot generate  sufficient  revenues to cover our
overhead, manufacturing and operating costs, we will fail.

COMPLIANCE WITH GOVERNMENTAL  REGULATIONS MAY IMPOSE ADDITIONAL COSTS, WHICH MAY
ADVERSELY AFFECT OUR FINANCIAL CONDITION AND RESULTS OF OPERATIONS.

            Because our cleaning  products are regulated by the Consumer Product
Safety Commission under authority of the Hazardous  Substances Act. The Consumer
Product Safety  Commission's  jurisdiction  covers most  non-cosmetic,  non-drug
substances  used in the home. The Federal agency  develops  voluntary  standards
with  industry and issues and  enforces  mandatory  standards  or bans  consumer
products if no  feasible  standard  would  adequately  protect  the  public.  It
conducts  research  on  potential  product  hazards  and  obtains  the recall of
products that it believes pose potential  risk for serious  injury or death,  or
arranges for their repair. Additionally,  the Consumer Product Safety Commission
informs and educates  consumers through the media,  state and local governments,
private  organizations  and by responding to consumer  inquiries on, among other
things,  what safety  features  to look for in  products.  We are not  currently
subject to direct federal,  state or local  regulation  other than the Hazardous
Substances Act and  regulations  applicable to businesses  generally or directly
applicable to retailing or electronic  commerce.  However,  from time to time in
the future,  Congress,  the FDA or any other  federal,  state,  local or foreign


                                       8


legislative and regulatory authorities may impose additional laws or regulations
that apply to us, repeal laws or regulations that we consider favorable to us or
impose more stringent  interpretations of current laws or regulations.  Any such
developments  could have a material  adverse  effect on our business,  financial
condition and results of operations.
    
IN THE EVENT THAT ONLY THE MINIMUM  OFFERING IS SOLD, WE MAY NOT HAVE SUFFICIENT
PROCEEDS TO IMPLEMENT OUR BUSINESS PLAN.

         If only  the  minimum  offering  is sold,  we may not  have  sufficient
proceeds to implement our sales,  marketing  and business  expansion or fund our
working capital. To the extent that other sources of funds are not available, we
will  not be able to  expand  operations  beyond  current  levels  and we may be
required to cease some or all of our operations.

RISKS RELATED TO THIS OFFERING

OUR UNITS,  COMMON STOCK AND  REDEEMABLE  CLASS A WARRANTS  HAVE NO PRIOR PUBLIC
TRADING MARKET AND WE CANNOT ASSURE LIQUIDITY FOR YOUR SECURITIES.

            Prior to this  offering,  there has been no active public market for
our units,  common stock or redeemable  class A warrants.  We cannot predict the
extent to which a trading  market  will  develop,  if at all, or how liquid that
market may become. The initial public offering price of our units,  common stock
and the exercise price of the class A redeemable  common stock purchase warrants
was  determined by us, based upon our assessment of our value compared to others
in our market and the general market for publicly  traded  securities.  This may
not be  indicative  of the market  price of our units after this  offering.  The
offering price of our units is not related to assets,  earnings,  book value, or
other criteria  traditionally  used to value companies.  You should not consider
the offering price as representative of the actual value of our units. The price
of our units is subject to change due to market conditions and other factors. We
cannot assure that you will be able to resell our units at the offering price.

OUR COMMON STOCK AND REDEEMABLE  CLASS A WARRANT PRICES MAY FALL UPON THE FUTURE
SALE OF ADDITIONAL SHARES OF OUR COMMON STOCK.

            Future sales of our common stock in the public  market,  or even the
possibility of such sales,  may materially and adversely affect the market price
of our common  stock and  redeemable  class A  warrants.  There were  33,952,636
shares of common stock  outstanding  before this offering.  Substantially all of
such shares are  "restricted  securities"  within the meaning of Rule 144 of the
Securities Act of 1933. All of these restricted  shares of our common stock will
become  eligible for resale under Rule 144 within one year from the day that the
shares  offered  herein  are deemed  "effective"  by the  Securities  & Exchange
Commission.

INVESTORS  WILL  EXPERIENCE  IMMEDIATE  AND  SUBSTANTIAL  DILUTION OF OUR COMMON
STOCK'S BOOK VALUE.

            If you purchase our units in this  offering,  the net tangible  book
value of the common stock will experience  immediate and  substantial  dilution.
Giving effect to the sale of the minimum number of offered units,  we would have
a net  tangible  book value of  approximately  $(.07) per share so that  persons
purchasing units in this offering would suffer an immediate dilution of $.32 per
share or 128% from the offering  price of $0.25 per unit.  Giving  effect to the
sale of the maximum number of units  offered,  our net tangible book value would
be approximately  $.00 per share or dilution to you of $.25 per share or 100% of
the public offering price. See "Dilution."

REDEMPTION  OF  REDEEMABLE  CLASS A WARRANTS  COULD DEPRIVE YOU OF YOUR RIGHT TO
EXERCISE YOUR WARRANTS.

            The  redeemable  class  A  warrants  are  redeemable  by  us,  at  a
redemption  price of $.001 per  warrant,  upon at least 30 days'  prior  written
notice,  commencing on __________,  2005 (six months after the date hereof),  if
the average of the closing high bid prices of the common stock exceeds $1.00 for
five consecutive trading days ending on the third day prior to the date on which
notice took effect. If the redeemable class A warrants are redeemed, the holders
will lose their  right to  exercise  their  warrants  except  during such 30 day
redemption period. Redemption of the redeemable class A warrants could force the
holders to exercise  the warrants at a time when it may be  disadvantageous  for
the holders to do so or to sell the warrants at the then current market value.

UNLESS THE PRICE OF OUR COMMON STOCK  TRADES ABOVE $0.50,  YOU MAY NEVER HAVE AN
OPPORTUNITY  TO  EXERCISE  YOUR  REDEEMABLE  CLASS A  WARRANTS,  RESULTING  IN A
COMPLETE LOSS OF THEIR VALUE.

            The redeemable  class A warrants are exercisable at a price of $0.50
per share.  Unless our common stock  trades  above that price,  you will have no
incentive  to exercise  the  warrants.  If our common stock does not trade above
$0.50 per share within five years,  there would be no reason for you to exercise
the warrants and they will become worthless.


                                       9


RISKS RELATED TO OUR COMMON STOCK

THERE IS  PRESENTLY  NO MARKET  FOR OUR  COMMON  STOCK AND SUCH  MARKET  MAY NOT
DEVELOP.

         At the present time,  no market for our common stock  exists.  A market
for our common stock is in large part  predicted on our future  earnings as well
as  our  ability  to  be  successfully   listed  on  an  exchange  such  as  the
Over-the-Counter  Bulletin  Board.  If are  not  approved  to be  traded  on the
Over-the-Counter Bulletin Board or if we do not generate revenue or a profit, no
market for our common stock may be developed.

OUR  COMMON  STOCK  MAY NOT BE ABLE TO  TRADE ON THE  OVER-THE-COUNTER  BULLETIN
BOARD. IF OUR STOCK IS UNABLE TO TRADE ON THE OTCBB, OUR INVESTORS MAY BE UNABLE
TO SELL THEIR SHARES PUBLICLY JEOPARDIZING OUR ATTEMPT TO FUND OUR OPERATIONS.

         We intend that our securities  trade on the  Over-the-Counter  Bulletin
Board. However, we can offer no assurance that our securities will so trade and,
if they do  trade  on the  OTCBB,  whether  an  active  trading  market  will be
established or, if established,  whether it can be maintained.  If our shares do
not trade on the  OTCBB,  they may  trade on the Pink  Sheets,  a  non-automated
market, with a consequential lack of liquidity.

OUR CONTROLLING  SHAREHOLDERS MAY EXERCISE SIGNIFICANT CONTROL OVER US FOLLOWING
THIS OFFERING, DEPRIVING OTHER STOCKHOLDERS OF THE ABILITY TO ELECT DIRECTORS OR
EFFECT OTHER CORPORATE ACTIONS.

            The shares offered in this prospectus  represent a minority  portion
of our outstanding voting shares. Before this offering, our directors, executive
officers and principal shareholders  beneficially owned approximately 80% of the
outstanding  shares of our common  stock.  Following  this  offering,  they will
beneficially own approximately 77% of our outstanding shares assuming completion
of the minimum  offering,  or approximately 66% if the maximum offering is sold.
Our  shareholders  do not have  cumulative  voting  rights  with  respect to the
election of directors.  If our principal shareholders vote together,  they could
effectively elect all of our directors. See "Principal Stockholders."

OUR  COMMON  STOCK IS  SUBJECT  TO THE  "PENNY  STOCK"  RULES OF THE SEC AND THE
TRADING MARKET IN OUR  SECURITIES IS LIMITED,  WHICH MAKES  TRANSACTIONS  IN OUR
STOCK CUMBERSOME AND MAY REDUCE THE VALUE OF AN INVESTMENT IN OUR STOCK.

         The  Securities  and Exchange  Commission  has adopted Rule 15g-9 which
establishes the definition of a "penny stock," for the purposes  relevant to us,
as any equity  security  that has a market price of less than $5.00 per share or
with an  exercise  price of less  than  $5.00  per  share,  subject  to  certain
exceptions.  For any  transaction  involving a penny stock,  unless exempt,  the
rules require:

      o     that a broker or dealer approve a person's  account for transactions
            in penny stocks; and

      o     the broker or dealer  receive from the investor a written  agreement
            to the  transaction,  setting forth the identity and quantity of the
            penny stock to be purchased.

         In order to  approve  a  person's  account  for  transactions  in penny
stocks, the broker or dealer must:

      o     obtain financial information and investment experience objectives of
            the person; and

      o     make a  reasonable  determination  that  the  transactions  in penny
            stocks are  suitable  for that person and the person has  sufficient
            knowledge  and  experience  in  financial  matters  to be capable of
            evaluating the risks of transactions in penny stocks.

         The broker or dealer must also deliver,  prior to any  transaction in a
penny stock, a disclosure  schedule prescribed by the Commission relating to the
penny stock market, which, in highlight form:

      o     sets  forth  the  basis on  which  the  broker  or  dealer  made the
            suitability determination; and

      o     that the broker or dealer received a signed,  written agreement from
            the investor prior to the transaction.


                                       10


         Generally,  brokers  may be less  willing  to execute  transactions  in
securities  subject to the "penny stock" rules.  This may make it more difficult
for  investors  to dispose of our common stock and cause a decline in the market
value of our stock.

         Disclosure  also has to be made about the risks of  investing  in penny
stocks  in  both  public  offerings  and in  secondary  trading  and  about  the
commissions payable to both the broker-dealer and the registered representative,
current  quotations for the securities and the rights and remedies  available to
an  investor  in cases of fraud in penny stock  transactions.  Finally,  monthly
statements  have to be sent  disclosing  recent price  information for the penny
stock held in the account and information on the limited market in penny stocks.

                                 USE OF PROCEEDS
 
         If the  minimum  number  of units are sold,  we  estimate  that we will
receive net proceeds of approximately $400,000 ($500,000 of gross proceeds, less
offering  expenses of $100,000) from our sale of the 2,000,000  units offered by
us. If the maximum  number of units are sold,  we estimate  that we will receive
net proceeds of  approximately  $1,900,000  ($2,000,000 of gross proceeds,  less
offering  expenses of $100,000) from our sale of the 8,000,000  units offered by
us. This  estimate is based on an initial  public  offering  prices of $0.25 per
unit and is before deduction for any commissions or non-accountable  expenses we
may pray to  registered  broker-dealers,  if any.  We have no  currently  plans,
arrangements or agreements to offer any units through registered broker-dealers.

We  expect  to use the net  proceeds  of the  "best  efforts"  offering  for the
following purposes: (1)

                                     Minimum         Maximum

Product development (2)             $100,000      $  700,000
Marketing (3)                        100,000         700,000
Payment of accounts                  100,000         100,000
    payable and indebtedness
Working capital                      100,000         400,000

      Total                         $400,000      $1,900,000

(1) Assumes that all product  development,  marketing and accounts  payable come
from the "best efforts" offering and not from operations.

(2) Products to be developed  from  prototype to  manufacturing  stages  include
household cleaning products and personal care products

(3) Marketing will include infomercials and international markets.

         We will not receive any proceeds from the 17,259,344  additional shares
of common  stock  subject  to  resale by the  selling  stockholders  under  this
prospectus.

            MARKET FOR COMMON EQUITY AND RELATED STOCKHOLDER MATTERS

MARKET FOR SECURITIES

         There is no market for our common stock.

         As of February 24, 2005, there were  approximately 50 holders of record
of our common stock.

         WE HAVE  APPOINTED  OLDE  MONMOUTH  STOCK  TRANSFER CO, INC.,  ATLANTIC
HIGHLANDS, NJ, AS TRANSFER AGENT FOR OUR SHARES OF COMMON STOCK.


                                       11


Equity Compensation Plan Information

         As of February 24, 2005, we have not had any equity  compensation plans
outstanding.

                                 DIVIDEND POLICY

         We have  not  paid  any  cash  dividends  on our  common  stock  and we
currently  intend to retain  any future  earnings  to fund the  development  and
growth of our business.  Any future determination to pay dividends on our common
stock will  depend  upon our  results of  operations,  financial  condition  and
capital  requirements,  applicable  restrictions  under any credit facilities or
other  contractual  arrangements  and such other factors deemed  relevant by our
Board of Directors.

                                    DILUTION

         As of November 30, 2004,  our net tangible book value was  $(1,897,463)
or $(.10)  per share of  common  stock.  Net  tangible  book  value per share is
determined  by dividing a company's  tangible  net worth (total  assets,  net of
intangible  assets,  less total liabilities) by the number of outstanding common
shares.  After giving effect to the conversion of trade payables and other loans
into  shares of common  stock and the  conversion  of shares of common  stock in
exchange  for services  performed on our behalf for an aggregate of  14,967,636,
and  assuming  the sale of the minimum  offering of  2,000,000  shares of common
stock,  the pro forma net tangible book value per share after the offering would
be (.07),  without taking into account any change in our net tangible book value
after November 30, 2004 and after deducting  estimated offering  expenses.  This
represents  an  immediate  increase in the net  tangible  book value of $.01 per
share to existing  shareholders.  The following table illustrates this per share
dilution:



                                                      ASSUMING                          ASSUMING
                                                      MINIMUM      50% of    75% of     MAXIMUM
                                                      OFFERING   OFFERING    OFFERING   OFFERING
                                                      --------   --------    -------    -------
                                                                               
Assumed public offering price per share               $0.25       $0.25       $0.25      $0.25
Net tangible book value per share as of
    November 30, 2004                                  (.10)
Increase per share attributable to this offering        .03         .06         .08       .10
Pro forma net tangible book value per share
       after this offering                             (.07)       (.04)       (.02)      .00

Dilution to new investors                               .32         .29         .27       .25
Percentage of Dilution                                  128%        116%        108%      100%


         The  following  table sets  forth the number of shares of common  stock
purchased from us, the total  consideration paid and the average price per share
paid by the existing shareholders and by new investors in this offering on a pro
forma basis as of November 30, 2004.



                                      Shares Purchased             Total Consideration       
                                  ----------------------        -----------------------    Average Price
                                    Number       Percent          Amount        Percent      Per Share
                                  ----------     -------        ----------      -------      ---------
                                                                                  
Assuming Minimum Offering:

Existing Shareholders             33,952,636       94.4%        $2,535,247       83.53%        $0.07
New Investors                      2,000,000        5.6%        $  500,000       16.47%        $0.25

Total                             35,877,636        100%        $3,035,247         100%        $0.08



                                 CAPITALIZATION

         The  following   table   summarizes  our  long-term   obligations   and
capitalization  as of  November  30,  2004,  and as  adjusted as of that date to
reflect (i) the sale of the  2,000,0000  units offered in the prospectus and our
application  of the estimated net  proceeds,  and after  deducting the estimated
offering  expenses.  The  information  in the table  assumes an  initial  public


                                       12


offering price of $0.25 per unit. The information in the table should be read in
conjunction  with the more  detailed  combined  financial  statements  and notes
presented elsewhere in this prospectus.



                                                                November 30, 2004
                                                            Actual     As Adjusted (1)
                                                         -----------   ---------------
                                                                          
Long-term obligations [including/less] current portion             0              0
Stockholders' equity:
Common stock $.001 par value;
   authorized [50,000,000] shares; issued
   and outstanding  shares                                    18,985         35,952
Preferred stock, $.001 par value;
   authorized 5,000,000 shares;
   no shares issued and outstanding                                0              0
Additional paid in capital                                   248,948      2,999,295
Common stock subscribed                                      526,814              0
Deficit                                                   (2,692,210)    (2,692,210)
Net Stockholders' equity (deficiency)                     (1,897,463)       343,037
                                                         -----------    -----------
Total capitalization (deficiency)                        $(1,897,463)   $   343,037
                                                         ===========    ===========


(1) Includes  the  conversion  of trade  payables and other loans into shares of
common stock and  issuance of shares in exchange  for services  performed on our
behalf for a total of  14,967,636  shares and  assumes  the sale of the  minimum
offering of 2,000,000 shares of common stock.


                      MANAGEMENT'S DISCUSSION AND ANALYSIS
                OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS

         The statements  contained in this prospectus are not purely  historical
statements,  but rather include what we believe are forward-looking  statements.
The  forward-looking  statements are based on factors set forth in the following
discussion  and in the  discussions  under "Risk  Factors" and  "Business."  Our
actual  results  could  differ  materially  from  results  anticipated  in these
forward-looking  statements.  All  forward-looking  statements  included in this
document are based on  information  available  to us on the date hereof,  and we
assume no obligation to update any such forward-looking statements.

OVERVIEW

         We  design,  produce,  market  and  distribute  cleaning  products  for
vehicular use utilizing  patented  technology  relating to hydrophilic  sponges,
which are liquid  absorbing,  foam  polyurethane  matrices.  Our products can be
pre-loaded  with  detergents  and waxes,  which are  absorbed in the core of the
sponge  then  released  gradually  during use.  We have also  designed  and have
started to test market,  but have not yet produced or sold,  products  using the
same  hydrophilic  technology  for bath and home  cleaning  use.  We license the
rights to  manufacture  and sell our products for vehicular use from H.H.  Brown
Shoe Technologies,  Inc., d/b/a Dicon  Technologies,  the holder of the relevant
patents relating to the hydrophilic sponges.

CORPORATE BACKGROUND

         We were formed on June 18, 1999, under the name Romantic  Scents,  Inc.
On June 12, 2001,  Romantic  Scents,  Inc.  changed its name to RSI Enterprises,
Inc., and, on October 2, 2002, changed its name to Spongetech International Ltd.
On July 15,  2002,  we  entered  into a stock  purchase  agreement  with  Nexgen
Acquisitions  VIII, Inc. pursuant to which our sole stockholder,  RM Enterprises
International, Inc. received 12,000,000 shares of Nexgen Acquisitions VIII, Inc.
and thereby became its majority  stockholder.  The transaction was accounted for


                                       13


as a reverse  acquisition  using the purchase  method of accounting,  whereby RM
Enterprises  International,  Inc., our sole shareholder,  retained approximately
63% of the  outstanding  common stock.  Thereafter,  on October 9, 2002,  Nexgen
Acquisitions VIII, Inc. changed its name to Spongetech Delivery Systems, Inc. On
December 16, 2002,  we changed our  domicile to  Delaware.  Spongetech  Delivery
Systems,  Inc. (formerly Nexgen Acquisitions VIII, Inc.) merged with and into us
so that we became the surviving company.  Immediately  subsequent to the merger,
we changed our name to Spongetech Delivery Systems, Inc.

RESULTS OF OPERATIONS  

SIX MONTHS ENDED NOVEMBER 30, 2004 AND 2003 

         Net  sales  for the six  months  ended  November  30,  2004  were $0 as
compared to $2,123 for the six months  ended  November  30,  2003, a decrease of
$2,123. Management attributes this decrease to its inability to promote, market,
and sell its automotive product due to lack of capital.

         We have no open  purchase  orders at this  time.  We have  consistently
depended on one customer for almost all of our sales.  If this customer does not
give us new orders in the future,  our operations  will not be profitable and we
will not be able to continue in business.

         During the six months ended  November 30, 2004, we had minimal sales of
$0. Our gross  profit  for the six  months  ended  November  30,  2004 was $0 as
compared to $(3,013)  for the six months ended  November  30,  2003.  Management
attributes this decrease in gross profit to no sales during this period.

         Operating  expenses  for the six months  ended  November  30, 2004 were
$17,172 as compared to $53,264  for the period  ended  November  30,  2003.  The
decrease  of  $36,092  is the result of a  decrease  of sales  expenses  for the
period.  Included in total  operating  expenses for the period November 30, 2003
were selling expenses of $25,052, general and administrative expenses of $25,462
and depreciation expense of $2,750.

         Net loss for the six months ended  November  30, 2004 was  ($17,172) or
($.01) per share as compared to a net loss of  ($56,277) or ($.01) per share for
the sixth  months ended  November 30, 2003.  The decrease in net losses were the
result of less  selling  expenses  for the six months  ended  November  30, 2004
compared to the six months ended November 30, 2003.

FISCAL YEARS ENDED MAY 31, 2004 AND 2003 

         Net sales  were  $1,858  for the  fiscal  year  ended  May 31,  2004 as
compared to $342,019  for the fiscal year ended May 31, 2003.  This  decrease is
primarily attributed to no capital for production.

         Cost of sales was $1,600 or 86% of net sales for the fiscal  year ended
May 31,  2004 as  compared to $299,617 or 87.6% of net sales for the fiscal year
ended May 31, 2003.

         Operating  expenses for the fiscal year ended May 31, 2004 increased to
$2,051,772  from $307,519 for the fiscal year ended May 31, 2003.  This increase
of  $1,744,253  was a result of increased  compensation  that was  exchanged for
stock.  Selling  expenses  for the  fiscal  year  ended  May 31,  2004  included
commissions of $3,552,  travel expenses of $3,538,  public  relations of $14,945
and  advertising of $17,500.  General and  administrative  expenses for the year
ended May 31, 2004  included the value of services  rendered by the officers and
consulting  expenses of  $1,953,631,  office  expenses of $14,973,  professional
expenses of $38,243,  telephone expenses of $1,842,  offering expenses of $1,250
and expenses relating to the factoring of our accounts receivable of $2,507.


         Net loss for the fiscal  year ended May 31,  2004 was  ($2,056,526)  or
($.01) per share as compared to net loss of ($265,517) or ($.01) per share.  The
increase in the net loss of  $1,791,009  in fiscal year 2004  compared to fiscal
year 2003 is the result of the  increase in expenses for  professional  fees and
compensation.


                                       14


LIQUIDITY AND CAPITAL RESOURCES 

         As of November 30, 2004,  we had cash of $20. We had cash of $50 at May
31,  2004.  During the six months  ended  November  30,  2004,  net cash used by
operating activities  aggregated $(30),  primarily attributed to the net loss of
$17,172  less  non-cash  expenses of  $15,000.  Net cash  provided by  financing
activities for the six months ended November 30, 2004 was 0.

         During  the six  months  ended  November  30,  2004,  net cash  used in
operating  activities  aggregated  $30 as  compared  to $38,640  used in the six
months  ended  November  30, 2003.  Net cash used by  operating  activities  was
primarily  attributed  to the net  loss of  $56,277  for  the six  months  ended
November 30, 2003.

         Net cash used in  investing  activities  during  the six  months  ended
November  30,  2004  aggregated  $0, as  compared to $728 used in the six months
ended November 30, 2003. This decrease is attributed to the purchasing of office
equipment in the six months ended November 30, 2003.

         Net cash  provided by  financing  activities  for the six months  ended
November  30,  2004 was $0 as compared  to $38,608  during the six months  ended
November  30,  2003.  This  increase is primarily  attributed  to proceeds  from
factoring and related party notes incurred  during the six months ended November
30, 2003.

         The only increase in accrued compensation between the fiscal year ended
May 31, 2004 and November 30, 2004 has been to accounting and professional fees.

         The working capital (deficiency) at November 30, 2004 was $1,928,152 as
compared to a working capital  (deficiency) of $1,913,122 at May 31, 2004. These
factors  create  substantial  doubt  about our  ability to  continue  as a going
concern.  The recovery of assets and the  continuation of future  operations are
dependent upon our ability to obtain additional debt or equity financing and our
ability to generate  revenues  sufficient  to  continue  pursuing  our  business
purpose.

         We  maintain  a  supply  and  requirements   agreement  with  Dicon,  a
manufacturing  company  that has the  technological  know-how  and  patented and
proprietary   information   relating  to  hydrophilic  foam  sponges  and  their
applications.  The  agreement,  which  grants us exclusive  worldwide  rights to
distribute the products was extended until July 2006 and requires us to purchase
all of our requirements from Dicon. Pursuant to the agreement,  we must purchase
minimum  annual  required  amounts  from Dicon.  We did not satisfy  last year's
requirements and paid $1,894.51 to Dicon in December 2003 in connection with the
missed  quantity  requirements.  We believe that this is the full amount that we
currently owe Dicon and have not accrued any additional amounts on our financial
statements

         It is extremely difficult to itemize the price of each sponge purchased
from  Dicon  because  the price  charged  includes  the  sponge  or sponge  kit,
packaging,  storage  and  shipping.  The  price for each  sponge or sponge  kit,
including these ancillary  items,  ranged from $.85 to $1.42.  The average price
per sponge or sponge kit was $1.12.

         We have purchased the following  sponge kits and sponges as of the date
of the prospectus:

         25,000 kits, each consisting of a vehicular  sponge,  detail sponge and
         chamois  cloths  
         168,600 vehicular sponges 
         4,500 detail sponges 
         2,200 chamois cloths.

         We are  currently in  negotiations  with a major  importer to South and
Central America for the purchase of 500,000 units allocated as follows:  150,000
single  sponges and 350,000 kits during the third and fourth  quarters of fiscal
year 2005,  subject to approval of the translation of the packaging into Spanish
and Portuguese. We cannot guarantee that these negotiations will result in sales
or that the sales will be profitable.


                                       15


                                    BUSINESS

SPONGETECH DELIVERY SYSTEMS 

         We  design,  produce,  market  and  distribute  cleaning  products  for
vehicular and home use utilizing  patented  technology  relating to  hydrophilic
(liquid absorbent) foam polyurethane matrices.

THE TECHNOLOGY 

         We  entered  into a  license  agreement  on July 1,  2001 for  patented
technology relating to hydrophilic  polyurethane matrices on an exclusive basis.
The technology is owned by and licensed from H.H. Brown Shoe Technologies, Inc.,
Greenwich,  Connecticut (d/b/a Dicon Technologies),  a majority-owned subsidiary
of Berkshire Hathaway, Inc. which owns the patent rights. Our license applies to
the cleaning and polishing of land, sea and air transportation vehicles. We have
an oral  understanding but no written agreements with Dicon that would permit us
to develop products using the same sponge  technology in other areas,  including
household cleaning and personal care.

         Our license is a continuing one for the full life of the design patent,
which was jointly developed by one of our former employees, and which covers the
design,  manufacture  and use of a  liquid-absorbent  layer in a "molded  sponge
design." The patent expires in 2017.

         The license agreement  mandates that we purchase our hydrophilic sponge
products from Dicon unless Dicon ceases its business operations,  either totally
or with respect to the  manufacture of the molded sponge design within the scope
of the design invention as set forth in the agreement.  If such event occurs, we
are permitted to use other manufacturers.

         Pursuant  to  the  license  agreement,   Dicon  retains  title  to  the
technology.  Thus,  when  the  license  expires,  we have to give up any and all
design rights to products that we have developed using the licensed  technology.
Dicon pays all expenses in connection  with filing and  maintaining  the patent.
Certain  minimum  quantities,  as set forth in the  requirements  agreement with
Dicon as discussed  below, are required to be purchased by us in order for us to
continue  its  exclusive  use of the  license.  Dicon  has  the  right,  without
restriction,  to license its  technology  in areas other than sponges for use in
cleaning and polishing transportation vehicles.

         The  technology  has also been used to draw fluids out of a human body,
such as body odors,  and store them in the polyurethane  matrix.  The technology
was  originally  contemplated  for use in shoe  liners,  incontinence  pads  and
nursing pads.  Currently,  companies  such as Payless Shoes and H.H.  Brown Shoe
Company (the  licensor) use the  technology  for inner soles to absorb sweat and
odors.  Revlon  is a  licensee  of the  technology  which it uses in a  cosmetic
make-up removal product.

         Our license is based on the  discovery  that if a sponge  incorporating
the  hydrophilic  matrix is filled with  detergents and waxes,  the matrix would
retain these  cleaning and polishing  agents and could only be released when the
sponge is  squeezed.  Thus,  soap or wax could be retained for many uses and the
sponge could be rinsed after use without losing the cleaning agent or wax.

SUPPLY AND REQUIREMENTS AGREEMENT 

         On July 1, 2001,  we entered  into an  exclusive  worldwide  supply and
requirements  agreement  with  Dicon  under  which we must  purchase  from Dicon
certain  minimum  quantities  of our sponges  containing  the Dicon  hydrophilic
matrix as follows:

         Annual Period                  Number of Sponge Products
         -------------                  -------------------------
         1st annual period                     250,000
         2nd annual period                     500,000
          and each succeeding
          annual period                      1,000,000

at the following prices:

         Aggregate Purchases            Price per sponge product
         -------------------             ----------------------
         50,000 to 100,000                  $.817 sponge only
         100,000 to 250,000                 $.795 sponge only
           Over 250,000                     $.778 sponge only


                                       16


         In the event the minimum  quantities  are not ordered in each  one-year
period,  we must  pay  Dicon  liquidated  damages  of $.20  per  sponge  for the
deficiency.  If we  fail  to pay the  damages  within  30 days of the end of the
annual period,  Dicon may terminate the license  agreement or render our license
non-exclusive  for all  subsequent  periods.  Dicon may,  after the first annual
period,  raise the prices it charges  for the sponges  only if such  increase is
based on bona fide  increases  in material  and labor costs plus an  appropriate
markup for  overhead.  The agreement was renewed until June 30, 2006. We may use
other  manufacturers  in the event of a breach by Dicon or in the event of force
majeure  which  prevents  production  for 90 days.  We  ordered in excess of the
minimum  quantity  for the  first  year of the  contract  but did not  order the
minimum  quantity  for the  remaining  two years of the original  agreement.  In
December 2003, we paid $1,894.51 to Dicon for any missed requirements.

         Dicon has designed and  installed  specialized  equipment for producing
molded  foam  products  containing  this  superabsorbent  polymer  infused  with
detergents,  soaps and waxes used as an absorbing and cleaning  sponge  product.
The agreement sets forth minimum purchase requirements and pricing for the basic
sponge  product.  Using its  patented  processes,  Dicon  manufactures  products
derived from "Hydrophilic  Urethane  Chemistry." The hydrophilic  system has two
parts,  a  hydrophilic  pre-polymer  phase and a water  phase.  During the water
phase,  various  water  soluble  active  ingredients  are  introduced  into  the
products.

PRODUCTS 

         We have  designed  specially  configured  sponges  containing  an outer
contact layer and an inner matrix.  Dicon, our licensor and manufacturer,  loads
the inner  matrix of the sponge  with  specially  formulated  soaps and,  in our
licensed  automotive  cleaning and  polishing  product,  soap and wax.  When the
sponge is applied to a surface with minimal  pressure,  the soap or soap and wax
are  simultaneously  applied to the surface.  When the sponge is not in use, the
hydrophilic matrix holds the soap so that it does not leech out of the sponge.

         We believe that our use of the patent has great marketing potential. We
can choose any  variety of  cleansers,  including  anti-bacterial  and  abrasive
soaps.  Thus,  we may  fine-tune  our  products  for use on  different  kinds of
vehicles.  New vehicles or those prepared for classic car shows require a gentle
cleaner,  whereas older cars which have developed a film over the paint or where
the paint has faded may require a cleanser containing a compounding substance, a
gentle abrasive.  Depending on the use of our vehicular  sponge,  we may include
wax, or may only include the cleanser.

SALES AND MARKETING 

         In February 2004, we inaugurated a website, www.spongetech.com, to sell
our vehicular cleaning kit directly to the public. Since inception, we have sold
approximately 500 kits for aggregate sales price of approximately $4,750. We pay
the website hosting company,  Harbor  Enterprises,  a 20% royalty from the sales
price on all Internet  sales.  We have not entered  into a contract  with Harbor
Enterprises.  Either party may terminate the  relationship  at any time. We ship
directly to customers.

         We have  developed a children's  bath foam  sponge,  with a "safe mesh"
coating which prevents tearing,  in the shape of animals in various colors.  The
sponges,  which  float,  are  infused  with  a  gentle  no-tear,  non-irritating
anti-bacterial  soap.  The bath foam  sponge  does not lose its soap while it is
floating in the bath tub as the inner hydrophilic  matrix retains the soap until
the child  squeezes the sponge in use. We are exploring  retail  outlets to sell
this product,  ranging from pharmacies to department  stores.  We also intend to
market  this  product  directly.  Dicon has orally  agreed to  manufacture  this
product for us. We have not yet made sales and cannot offer any assurances  that
sales will result from our proposed marketing campaign.


                                       17


         We have developed prototypes of household cleaning sponges infused with
anti-bacterial  bath and kitchen  soaps.  The  products  are being  testing by a
national  detergent  manufacturer  for possible use under its logo and brand. We
cannot predict whether or not the manufacturer will purchase our sponges and, if
it does, whether the product will succeed in the marketplace.

NEW PRODUCT DEVELOPMENT 

         Our new product development program consists principally of devising or
testing new products,  improving the efficiency of existing ones, evaluating the
environmental compatibility of products and market testing. We estimate that our
management  devotes 2,000 hours to  developing a product,  its packaging and its
marketing campaign. We have never paid nor do we expect to ever have to pay cash
compensation  for any product  development  activities.  We are  considering the
expansion  of our  product  lines to include  household  cleaning  products  and
personal hygiene products.  Dicon produced samples for us of our children's bath
foam sponge and household  cleaning sponge.  We have not yet signed an agreement
with Dicon in connection with the children's bath or household cleaning sponges.

NEW MARKETING 

         We are  working  on an  agreement  to sell our  vehicular  sponge to an
exporter of  automotive  products to South  America,  subject to the  exporter's
approval of both Spanish and Portuguese  language  translations of the product's
packaging.  TurtleWax and the Home  Shopping  Network have  indicated  that they
would like to continue their relationships with us and we are seeking expand the
range of products that we sell to our home line.  We cannot  warrant that any of
these discussions will result in contracts or purchase orders.

COMPETITION 

         We compete with  international,  national and local  manufacturers  and
distributors of soaps, detergents,  waxes, sponges, cloths and other automotive,
household and bath  products.  Indirectly,  in the  automotive  product area, we
compete with drive-through car washes.  Our competition,  for the most part, has
brand  recognition and large marketing and  advertising  budgets.  We face major
multinational competition in our proposed household and children's bath sponges.
Although our product is unique and patented, we cannot predict its acceptance in
any of the marketplaces for which it is designed.

         We compete on the basis of the uniqueness of our sponge, which combines
efficiency and effectiveness  compared to other vehicular cleaning products. Our
product avoids the preparation  and clean-up of using sponges,  liquid soaps and
pails of water.  It also avoids the mess and limited storage life of traditional
liquid and paste waxes. In addition, our cleaning and wax product is much easier
to apply and does not have to be buffed.  Our sponge which combines soap and wax
is  considerable  cheaper  than the  purchase  of the  individual  cleaning  and
application  products,  and our cleaning product is less expensive than the cost
of a sponge and liquid detergent.

         We have in the past and intend to again explore retail markets, such as
Home  Shopping  Network  to sell and  provide  greater  public  exposure  to our
vehicular sponge product.
 
EMPLOYEES 

         We currently  employ five people on a part-time basis of whom three are
members of the business and sales management team and two are staff.

                             DESCRIPTION OF PROPERTY

         Since December 8, 2004, we have been  occupying our principal  offices,
which  consist of 800 square feet of office  space  located at The Empire  State
Building,  350 Fifth Avenue,  Suite 2204, New York, New York 10118. The premises
are leased by members of the family of Steven Moskowitz, our secretary. Pursuant
to a  sublease  agreement,  we  paid  60,000  shares  of  our  common  stock  as
consideration  for the sublease.  We pay directly for  telephone,  utilities and
other expenses.


                                       18


                                LEGAL PROCEEDINGS

         Except as described  below, we are not currently a party to, nor is any
of our property currently the subject of, any pending legal proceeding.  None of
our directors, officers or affiliates is involved in a proceeding adverse to our
business or has a material interest adverse to our business.

         We are aware of a lawsuit commenced against,  among others,  Spongetech
International,  Ltd. by Westgate Financial Corporation although, to date, it has
not been  formally  served.  Plaintiff  asserts a breach of contract  against us
seeking  damages  of  $11,049.82  with  interest  accrued  thereon,   costs  and
reasonable  attorney's fees. We intend to vigorously  defend this matter once it
is duly served.

                                   MANAGEMENT

EXECUTIVE OFFICERS, DIRECTORS, DIRECTOR NOMINEES AND KEY EMPLOYEES 

         The  following  table  sets forth  certain  information  regarding  our
current Executive Officers, Directors and Key Employees:

Name                          Age      Position                          Since
------------------------      ---      -------------                     ------
Michael Metter*               53       President,
                                       Chief Executive Officer,
                                       Director                          5/2001

Steven Moskowitz*             40       Secretary,
                                       Director                          6/1999

Frank Lazauskas               44       Director                          7/2001

Thomas Monahan                57       Chief Financial Officer           3/2004

---------
* Michael Metter and Steven Moskowitz are promoters of Spongetech.  In addition,
RM Enterprises  International,  Jerome Schlanger and Michael Sorrentino were our
promoters.


BACKGROUND OF OFFICERS AND DIRECTORS

Michael Metter has been President,  Chief Executive Officer and a Director since
May 2001.  Mr. Metter has served as President of RM  Enterprises  International,
Inc., our majority  stockholder,  since April,  2001, and as its Chief Executive
Officer  since  March 2,  2004.  He has been a  director  of  Western  Power and
Equipment Corp. (OTCBB) since February, 2003. Mr. Metter served as the President
of Azurel,  Ltd.  (OTCBB and  subsequently  Pink  Sheets)  from  October 2002 to
February  2003,  and as its Chief  Operating  Officer  from October 2002 to June
2003.  Since June 2002,  Mr. Metter has served as President and Chief  Executive
Officer of BusinessTalkRadio.net, a syndicated radio network based in Greenwich,
Connecticut.  Since  June  2003,  he has been  chairman  of the board of Tiburon
Capital Group, a privately held holding corporation.  He was compliance director
of Securities Capital Trading,  Inc., a securities  broker-dealer,  from October
1998 to  February  2001.  On April 19,  2001,  Mr.  Metter  filed a petition  in
personal bankruptcy in the District of Connecticut, Bridgeport Division, and was
discharged on December 14, 2001. Mr. Metter  received his MBA in Finance in 1975
and his B.A. in Marketing and Accounting in 1973 from Adelphi University.


                                       19


Steven  Moskowitz has been Secretary,  Treasurer and a Director since June 1999.
Mr.  Moskowitz has served as a director of RM  Enterprises  International,  Inc.
since  April  2001,  and as its  Secretary  since  March 2, 2004.  He has been a
director of Western Power and Equipment  Corp.  (OTCBB) since February 11, 2003.
Mr. Moskowitz was CEO of Azurel,  Ltd, (OTCBB and subsequently Pink Sheets) from
October 31, 2002 to October 10, 2003. He served as Vice President, Marketing and
Business  Development  for H. W.  Carter & Sons,  a  distributor  of  children's
clothing,  from  1987 to  2002.  He was  President  of the H. W.  Carter  & Sons
division of Evolutions,  Inc. from 1996 to 1997. Mr. Moskowitz served in various
capacities  at  Smart  Style  Industries,  a  manufacturer  and  distributor  of
children's  apparel,  from 1986 to 1987 from sales  assistant to Vice  President
Sales and  Marketing.  He received his B.S. in Management  from Touro College in
1986.

Frank  Lazauskas  has been a  Director  since July 2001.  Mr.  Lazauskas  is the
founder and President of FJL Enterprises, Inc. and TNJ Enterprises, Inc., formed
in 1999 and  1997,  respectively,  which own and  operate  eight  Dominos  Pizza
Stores.  He was elected a director of RM  Enterprises  International,  Inc., our
majority  stockholder,  in March 2004. He received his B.A. in Mathematics  from
Central Connecticut State University in 1983.

Thomas  Monahan has been Chief  Financial  Officer since March 2004. Mr. Monahan
has been  self-employed as a Certified Public Accountant since 1987. Mr. Monahan
received his B.S. in Accounting from Rutgers  University in 1970 and his M.A. in
Marketing and  Distributive  Education from Montclair State College,  Montclair,
New Jersey in 1975.  Pursuant to our bylaws,  our  directors  are elected at our
annual  meeting  of  stockholders  and each  director  holds  office  until  his
successor  is  elected  and  qualified.  Officers  are  elected  by our Board of
Directors and hold office until an officer's  successor has been duly  appointed
and qualified unless an officer sooner dies, resigns or is removed by the Board.
There  are no family  relationships  among any of our  directors  and  executive
officers.

DIRECTOR COMPENSATION 

Our directors do not receive cash  compensation  for their services as directors
but are reimbursed for their  reasonable  expenses for attending board and board
committee meetings.

COMMITTEE OF THE BOARD OF DIRECTORS 

We have an audit committee composed of Frank Lazauskas and Thomas Monahan.

                             EXECUTIVE COMPENSATION

The following table sets forth for the fiscal years ended May 31, 2004 and 2003,
the  compensation  we paid  to our  Chief  Executive  Officer(s)  and any  other
executive officers who earned in excess of $100,000 based on salary and bonus.


                           SUMMARY COMPENSATION TABLE



                                                                                              LONG-TERM
                                                                                            COMPENSATION
                                                                             --------------------------------------------
                                               ANNUAL COMPENSATION                      AWARDS                PAYOUTS
                                       ------------------------------------  ------------------------------ -------------
                                                                                                                           ALL
                                                                   OTHER                       SECURITIES                 OTHER
                                                                  ANNUAL       RESTRICTED      UNDERLYING                COMPEN-
          NAME AND                                                COMPEN-     STOCK AWARD(S)    OPTIONS/       LTIP      SATION
     PRINCIPAL POSITION        YEAR     SALARY ($)   BONUS ($)  SATION ($)         ($)          SARs (#)    PAYOUTS ($)     ($)
---------------------------  -------   ------------- ---------- -----------  ----------------  ------------ -----------  --------
                                                                                                    
Michael Metter                2004         0           0           0               0              0             0           0
 Chief Executive Officer      2003         0           0           0               0              0             0           0



OPTION GRANTS FOR THE FISCAL YEARS ENDED MAY 31, 2004 AND 2003 

No options or SARS were granted to the named  executive  officers  during fiscal
year ended May 31, 2004.


                                       20


AGGREGATED  OPTION EXERCISE FOR THE FISCAL YEARS ENDED MAY 31, 2004 AND 2003 AND
FISCAL YEAR-END OPTION VALUES

None.

SECURITIES AUTHORIZED FOR ISSUANCE UNDER EQUITY COMPENSATION PLANS 

         The  following  table  shows  information  with  respect to each equity
compensation  plan under which our common stock is authorized for issuance as of
the fiscal year ended May 31, 2004.

                      EQUITY COMPENSATION PLAN INFORMATION



------------------------------------ ------------------------ ----------------------- ---------------------------
           Plan category              NUMBER OF SECURITIES       WEIGHTED AVERAGE        NUMBER OF SECURITIES
                                        TO BE ISSUED UPON       EXERCISE PRICE OF      REMAINING AVAILABLE FOR
                                           EXERCISE OF         OUTSTANDING OPTIONS,     FUTURE ISSUANCE UNDER
                                      OUTSTANDING OPTIONS,     WARRANTS AND RIGHTS    EQUITY COMPENSATION PLANS
                                       WARRANTS AND RIGHTS                              (EXCLUDING SECURITIES
                                                                                       REFLECTED IN COLUMN (a)
------------------------------------ ------------------------ ----------------------- ---------------------------
                                               (a)                     (b)                       (c)
------------------------------------ ------------------------ ----------------------- ---------------------------
                                                                                        
EQUITY COMPENSATION PLANS APPROVED             -0-                     -0-                       -0-
BY SECURITY HOLDERS
------------------------------------ ------------------------ ----------------------- ---------------------------
EQUITY COMPENSATION PLANS NOT                  -0-                     -0-                       -0-
APPROVED BY SECURITY HOLDERS
------------------------------------ ------------------------ ----------------------- ---------------------------
TOTAL                                          -0-                     -0-                       -0-
------------------------------------ ------------------------ ----------------------- ---------------------------


                 CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS

         We were  incorporated  in New York State on July 18,  1999 as  Romantic
Scents, Inc. by RM Enterprises International, Inc. which was issued 5,000 shares
representing  all our issued and outstanding  capital stock in  consideration of
forming  our  company.   During  fiscal  2001,  RM   Enterprises   International
contributed   $105,100,   fiscal  2002,  RM  Enterprises   International,   Inc.
contributed  $86,943,  during fiscal 2003, $63,050, and during fiscal year 2004,
$15,000. These advances were all paid back to RM Enterprises  International.  RM
Enterprises  International,  Inc. may be considered a promoter.  Michael Metter,
our President,  and Steven Moskowitz,  our Secretary, may also be considered our
promoters.  Jerome Schlanger and Michael Sorrentino were former presidents of us
and may be considered promoters. Aside from the shares of our common stock which
it received in connection  with our formation,  RM  Enterprises  has received no
additional  consideration from us for its activities related to our formation or
business.

         The control persons of RM Enterprises International are Michael Metter,
Steven  Moskowitz  and  Frank  Lazauskas,  all  of  whom  are  directors  of  RM
Enterprises International.

 (1) The Mindy Moskowitz and Steven Moskowitz Trust for Mindy Moskowitz,  Daniel
Moskowitz,  Ilana Moskowitz and Gitty Moskowitz is the owner of 1,316,890 shares
of the capital  stock.  Trustees are Mindy  Moskowitz,  wife, and Susan Weisman,
sister of Steven Moskowitz, our Secretary. Steven Moskowitz disclaims beneficial
ownership of these shares.

(2) The trustees of The Rubin Family  Irrevocable  Stock Trust are Majorie Rubin
and Robert Shulman, CPA. The beneficiaries of The Rubin Family Irrevocable Stock
Trust are Linda Rubin, Andrew Rubin and Lisa Rubin. The Rubin Family Irrevocable
Stock Trust owns 2,000,000  shares of our common stock and 459,657 shares of the
capital stock of RM Enterprises.


                                       21


(3) Jerome  Schlanger was Treasurer and a director of RM  Enterprises  until his
resignation  as of  March  3,  2004.  On July 15,  2002,  under  the name of RSI
Enterprises, we entered into a stock exchange agreement with Nexgen Acquisitions
under  which we  became a  wholly-owned  subsidiary.  Our sole  stockholder,  RM
Enterprises,   received   12,000,000  shares  of  the  common  stock  of  Nexgen
Acquisitions VIII and became its majority  stockholder.  Guy Cohen, as the owner
of Nexgen Holdings,  Inc., the parent of Nexgen Acquisitions was the promoter of
Nexgen Acquisitions; and he received no additional consideration from us for his
activities.  Mr. Cohen, on November 22, 2004, transferred his interest in Nexgen
Holdings to The Rubin Family Irrevocable Trust.

         In September,  2002, the major stockholder of Nexgen  Acquisitions VIII
transferred  2,000,000  shares to The Rubin Family  Irrevocable  Stock Trust,  a
stockholder  of RM  Enterprises,  but not a control  person  of RM  Enterprises,
300,000 shares to Eugene Dworkis,  200,000 shares to Maurice Harroch and 500,000
shares to Falcon Crest Capital, Inc.

         Michael  Sorrentino,  a former employee,  loaned us $25,000 on February
21, 2001 payable on demand. We had been accruing interest at the rate of 10% per
annum. Between June 1, 2000 to May 31, 2001, RM Enterprises International, Inc.,
our majority  stockholder,  loaned us during the fiscal year ended May 31, 2001,
an aggregate of $51,930.  The loan did not bear interest,  and the maturity date
was extended to December  31, 2004.  From  November,  2002 through  November 30,
2003, RM Enterprises International loaned us an aggregate of $73,600, payable on
demand.  The loan which was now due December 31, 2004 did not bear interest.  We
used these  funds to pay rent in the amount of $15,000,  telephone  costs in the
amount of $7,500 and other administrative  expenses relating to our occupancy of
our  headquarters  premises of $51,100.  All of these loans were  converted into
shares of our common stock.

         In January 2003, we paid $24,500 to a company owned by Deborah  Metter,
the wife of  Michael  Metter,  our  President,  for  marketing  and  promotional
services in connection  with the preparation of an infomercial for the vehicular
sponge,  including  the use of her home.  In 2003 and the first half of 2004, we
marketed  our  products on a radio talk show aired by  BusinessTalkRadio.net,  a
syndicated   radio   network  of  which  Mr.   Metter  is  President   and  CEO.
BusinessTalkRadio.net  received a $1.00  commission  on each item sold.  We paid
BusinessTalkRadio.net an aggregate of $300 during that time but currently do not
advertise on the program.

         From our inception in July 1999 until March 2, 2004, we occupied office
and  warehouse  space  in  premises  in  an  industrial  building  leased  by RM
Enterprises International.  We paid RM Enterprises International an aggregate of
$15,000 for rent,  $7,500 for  telephone  costs and  $51,600 for  administrative
costs.  From March 3, 2004 through  December 15, 2004, we occupied  office space
rent-free in an office tower that was leased by the family of Steven  Moskowitz.
We currently  sublease office space from A&N Enterprises LLC, which is leased by
the family of Steven  Moskowitz.  We issued 60,000 shares of common stock to A&N
Enterprises as consideration for our use of the premises.

         In January 2005,  we issued and  aggregate of 10,030,000  shares of our
common  stock to our  officers  and  directors,  as  compensation  for  services
performed on our behalf.

         In January 2005, we issued 533,333 shares of our common stock to Steven
Moskowitz, our Secretary and Director, in exchange for $80,000 in debt.

         In January  2005,  we issued  466,667  shares of our common stock to RM
Enterprise International and 215,969 shares of our common stock to Flo Weinberg,
Inc., its wholly-owned subsidiary, in exchange for $106,527.25 in debt.

          In January  2005,  we issued  466,667  shares of our  common  stock to
American  United  Global,  Inc.,  which is  majority-owned  by The Rubin  Family
Irrevocable Stock Trust, in exchange for $70,000 in debt.

         In  January  2005,  we issued  500,000  shares of our  common  stock to
Michael Sorrentino, in exchange for $75,000 in debt.


                                       22


         We believe that these  transactions were on terms as favorable as could
have been obtained from unaffiliated third parties.  All future  transactions we
enter into with our directors,  executive  officers and other affiliated persons
will  be on  terms  no  less  favorable  to us  than  can be  obtained  from  an
unaffiliated  party  and will be  approved  by a  majority  of the  independent,
disinterested  members of our board of  directors,  and who had  access,  at our
expense, to our or independent legal counsel.

         SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT

          The following table sets forth certain information, as of February 24,
2005, with respect to the beneficial  ownership of the outstanding  common stock
by (i) any  holder of more than five (5%)  percent;  (ii) each of our  executive
officers and  directors;  and (iii) our directors  and  executive  officers as a
group. Except as otherwise indicated,  each of the stockholders listed below has
sole voting and investment power over the shares beneficially owned.



-------------------------------- -------------------------- -------------------------------------------------
                                                             Shares of Common Stock Beneficially Owned(1)(2)
-------------------------------- -------------------------- -------------------------------------------------
           Name                         Title                      Number                      Percent
-------------------------------- -------------------------- ------------------------- -----------------------
                                                                                         
RM Enterprises International,                                    12,482,636                     36.5%
Inc. (3)
1350 Broadway, Suite 210,
New York, New York 10018
-------------------------------- -------------------------- ------------------------- -----------------------
Rubin Family Irrevocable                                          7,377,667                     21.4%
  Stock Trust (4)
25 Highland Boulevard
Dix Hills, New York 11746
-------------------------------- -------------------------- ------------------------- -----------------------
Michael Metter (3)(5)            President and Director          14,147,636                     30.5%
One Tinker Lane
Greenwich, CT 06830
-------------------------------- -------------------------- ------------------------- -----------------------
Steven Moskowitz (3)(6)          Secretary and Director          15,285,969                     32.9%
1350 Broadway, Suite 210
New York, NY 10018
-------------------------------- -------------------------- ------------------------- -----------------------
Thomas Monahan                   Chief Financial Officer            100,000                        *
3638 Oxford Avenue
Riverdale, New York 10463
-------------------------------- -------------------------- ------------------------- -----------------------
Frank Lazauskas (3)(7)           Director                        15,812,636                     34.1%
51 Niagara Street
Newark, New Jersey 07105
-------------------------------- -------------------------- ------------------------- -----------------------
Officers and Directors                                           20,280,969                     59.7%
(4 persons)
-------------------------------- -------------------------- ------------------------- -----------------------


* less than 1%

(1) Beneficial  ownership is determined in accordance  with the rules of the SEC
and generally  includes  voting or investment  power with respect to securities.
Unless otherwise indicated below, the persons and entity named in the table have
sole voting and sole  investment  power with respect to all shares  beneficially
owned, subject to community property laws where applicable.  Under rules adopted
by the SEC,  shares of common stock issuable  pursuant to warrants or options or
upon  conversion  of  convertible  securities,  to the extent  such  warrants or
options or  convertible  securities  are currently  exercisable  or  convertible
within 60 days of the date of the  prospectus,  are treated as  outstanding  for
computing  the  percentage  of the person  holding such  securities  but are not
treated as outstanding for computing the percentage of any other person.

(2) The percentage of beneficial  ownership is based on  33,952,636shares of our
common stock outstanding as of the date of the prospectus.

(3) Includes  12,266,667  shares of our common  stock and 215,969  shares of our
common  stock owned by Flo  Weinberg,  Inc.,  a  wholly-owned  subsidiary  of RM
Enterprises  International.  The control persons of RM Enterprises International


                                       23


are  Michael  Metter,  Steven  Moskowitz  and Frank  Lazauskas,  all of whom are
directors of RM Enterprises International.

(4) Includes  6,911,000  shares of our common stock and 466,667 shares of common
stock  owned by  American  United  Global,  Inc.,  of  which  The  Rubin  Family
Irrevocable  Stock is a majority  stockholder.  The trustees of The Rubin Family
Irrevocable  Stock  Trust  are  Majorie  Rubin  and  Robert  Shulman,  CPA.  The
beneficiaries  of The Rubin  Family  Irrevocable  Stock  Trust are Linda  Rubin,
Andrew Rubin and Lisa Rubin. The Rubin Family  Irrevocable Stock Trust also owns
459,657 shares of the capital stock of RM Enterprises International.

(5) Includes  1,665,000  shares of our common  stock.  Deborah  Metter,  wife of
Michael Metter,  our President,  is the beneficial  owner of 1,768,470 shares of
our common stock  representing  her  ownership of 103,470  shares of the capital
stock of RM Enterprises  International  and 1,665,000 shares of our common stock
held by her through her  corporation,  D.L.  Investments,  Inc.  Michael  Metter
disclaims beneficial ownership of the shares held by Deborah Metter.

(6) Includes  2,803,333  shares of our common  stock.  The Mindy  Moskowitz  and
Steven Moskowitz Trust for Mindy Moskowitz,  Daniel  Moskowitz,  Ilana Moskowitz
and Gitty  Moskowitz is the beneficial  owner of 1,316,890  shares of our common
stock  through its  ownership  of  1,316,890  shares of the capital  stock of RM
Enterprises  International.  Trustees  are  Mindy  Moskowitz,  wife,  and  Susan
Weisman,  sister of Steven  Moskowitz,  our secretary.  Mr. Moskowitz  disclaims
beneficial ownership of these shares.

(7)  Includes   3,330,000  shares  of  our  common  stock.  Mr.  Lazauskas  also
owns1,088,002 shares of the capital stock of RM Enterprises International.


                            DESCRIPTION OF SECURITIES
 
         The  following  description  of our  capital  stock is a summary and is
qualified in its entirety by the provisions of our Certificate of Incorporation,
with  amendments,  all of which have been filed as exhibits to our  registration
statement of which this prospectus is a part.

CAPITAL STRUCTURE

         Our authorized  capital stock consists of 55,000,000  shares of capital
stock,  par value $.001 per share, of which  50,000,000  shares are common stock
and  5,000,000  shares  are  preferred  stock  that may be issued in one or more
series at the  discretion  of the  board of  directors.  As of the date  hereof,
33,877,636  shares of common stock and no shares of  preferred  stock are issued
and outstanding.

UNITS

         Each unit offered hereby  consists of one share of common stock and one
redeemable  class A warrant.  The  components of the unit will not be separately
transferable  for a period of 90 days from the initial closing of this offering,
or sooner in our  discretion.  We will issue a press  release if we determine to
allow the common  stock and class A  redeemable  warrants  to become  separately
tradable prior to 90 days.

COMMON STOCK 

         We are authorized to issue 50,000,000 shares of common stock, $.001 par
value per share, of which  33,952,636shares are issued and outstanding as of the
date of the prospectus.  Each  outstanding  share of common stock is entitled to
one vote, either in person or by proxy, on all matters that may be voted upon by
their holders at meetings of the stockholders.

         Holders of our common stock:

      o     have equal ratable rights to dividends from funds legally  available
            therefore, if declared by our board of directors;


                                       24


      o     are  entitled to share  ratably in all of our assets  available  for
            distribution  to  holders  of  common  stock  upon our  liquidation,
            dissolution or winding up;

      o     do not  have  preemptive,  subscription  or  conversion  rights,  or
            redemption or sinking fund provisions; and

      o     are entitled to one  noncumulative  vote per share on all matters on
            which stockholders may vote at all meetings of our stockholders.

         Cumulative  voting for the election of directors is not provided for in
our certificate of incorporation,  which means that the holders of a majority of
the shares voted can elect all of the directors then standing for election.

         Our certificate of incorporation provides that specified provisions may
not be repealed or amended  except upon the  affirmative  vote of the holders of
not less than 2/3 of the  outstanding  stock  entitled to vote.  This  provision
would  enable  the  holders  of more  than 1/3 of our  voting  stock to  prevent
amendments to the certificate of incorporation  even if they were favored by the
holders of a majority of the voting stock.

PREFERRED STOCK 

         We may, subject to limitations prescribed by Delaware law:

      o     provide for the issuance of up to 5,000,000  shares of our preferred
            stock in one or more series;

      o     establish  from time to time the number of shares to be  included in
            each such series;

      o     fix the rights,  preferences  and  privileges  of the shares of each
            wholly  unissued  series  and  any  qualifications,  limitations  or
            restrictions thereon; and

      o     increase  or  decrease  the number of shares of any such series (but
            not below the number of shares of such series then outstanding)

without any further vote or action by the stockholders.

         Our board of directors may  authorize  the issuance of preferred  stock
with voting or conversion rights that could adversely affect the voting power or
other  rights of the holders of our common  stock.  The  issuance  of  preferred
stock, while providing  flexibility in connection with possible acquisitions and
other  corporate  purposes,  could,  among  other  things,  have the  effect  of
delaying,  deferring or preventing a change in control and may adversely  affect
the  market  price of the common  stock and the  voting and other  rights of the
holders  of  common  stock.  We have no  current  plans to issue  any  shares of
preferred stock.

REDEEMABLE CLASS A WARRANTS

         Each redeemable class A warrant entitles the registered  holder thereof
to  purchase  one share of common  stock  form us at a price of $0.50 per share,
subject to  adjustment in certain  circumstances,  at any time from the date the
warrants become separately tradable until five years after the date hereof.

         We may redeem the class A warrants at a redemption  price of $0.001 per
class A warrant, upon at least 30 days' written notice, commencing on _________,
2005 (six months after the date hereof),  if the average of the closing high bid
prices of the common  stock  exceeds  $1.00 for five  consecutive  trading  days
ending  on the third day  prior to the date on which  notice  of  redemption  is
given,  and  provided  that a  current  prospectus  relating  to the  underlying
securities  is then in effect.  All of the  redeemable  class A warrants must be
redeemed if any are  redeemed.  We will redeem the warrants if we are in need of
additional capital at a time when the common stock is trading above $1.00 and we
believe that other sources of capital are less advantageous.


                                       25


         The  exercise  prices  and  number of  shares of common  stock or other
securities issuable upon exercise of the redeemable class A warrants are subject
to  adjustment  in  certain  circumstances,  including  in the  event of a stock
dividend,   stock   split,   recapitalization,    reorganization,    merger   or
consolidation.

         The redeemable  class A warrants may be exercised upon surrender of the
warrant  certificate  on or prior to the  expiration  date at the offices of the
warrant  agent,  with  the  exercise  form on the  reverse  side of the  warrant
certificate completed and executed as indicated,  accompanied by full payment of
the exercise  price to the warrant  agent for the number of  redeemable  class A
warrants being exercised. Holders of the redeemable class A warrants do not have
the rights or privileges of holders of common stock.

         In order to comply with applicable laws in connection with the exercise
of the  redeemable  class A warrants  and the resale of the common  stock issued
upon such exercise, the redeemable class A warrants will be exercisable only if:

      o     at  the  time  of  exercise,   we  have  an  effective  and  current
            registration  statement  on file with the  Securities  and  Exchange
            Commission  covering  the  shares  of  common  stock  issuable  upon
            exercise upon such redeemable class A warrant; and

      o     such shares have been registered or qualified or deemed to be exempt
            from registration or qualification  under the securities laws of the
            state of residence of the holder of such redeemable class A warrant.

         We will use our  best  efforts  to have all  shares  so  registered  or
qualified  on or before any exercise  date and to maintain a current  prospectus
relating  thereto  until the  expiration  of the  redeemable  class A  warrants,
subject to the terms of the warrant  agreement.  While it is our intention to do
so, there is no assurance  that it will be able to comply.  We therefore will be
required to file post-effective  amendments to this registration  statement when
subsequent  events require such amendments in order to continue the registration
of the common  stock  underlying  the  redeemable  class A warrants  and to take
appropriate  action  under  state  laws.  During  any period in which we fail to
maintain the effectiveness of this registration  statement,  the  warrantholders
will not be able to exercise their redeemable class A warrants.

REPORTS TO STOCKHOLDERS 

         We intend to furnish our  stockholders  with annual reports  containing
audited financial statements as soon as practicable after the end of each fiscal
year. Our fiscal year ends on May 31.

TRANSFER AGENT 

         We have appointed  Olde Monmouth  Stock  Transfer Co.,  Inc.,  Atlantic
Highlands,  New  Jersey,  as transfer  agent for our shares of common  stock and
warrants.

                              SELLING STOCKHOLDERS

         We are  registering  17,259,344  of the shares,  which are owned by our
stockholders.  We will not  receive  any of the  proceeds  from  sales of shares
offered under this prospectus.

         All costs, expenses and fees in connection with the registration of the
selling stockholders' shares will be borne by us. All brokerage commissions,  if
any, attributable to the sale of shares by selling stockholders will be borne by
selling stockholders.

         The following  table sets forth the name of each person who is offering
the resale of shares of common stock by this prospectus, the number of shares of
common stock  beneficially  owned by each person, the number of shares of common
stock that may be sold in this offering and the number of shares of common stock
each person will own after the  offering,  assuming  they sell all of the shares
offered.


                                       26




                                        Shares Beneficially Owned                    Shares Beneficially Owned
                                          Prior to the Offering                        After the Offering (1)
                                        ------------------------                  ---------------------------------
                                                                       Total          Percent          Percent
              Name                      Number       Percent (2)      Shares          Assuming         Assuming
                                                                    Registered    Minimum Offering  Maxium Offering
--------------------------------        ------       -----------    ----------    ----------------  ---------------
                                                                                         
Shinya Araki                             5,000           *              5,000          -0-%            -0-%
Neil Foley                               5,000           *              5,000          -0-%            -0-%
Jean Geyer                              10,000           *             10,000          -0-%            -0-%
Emma Hass                                8,000           *              8,000          -0-%            -0-%
Melvin Koeller                           5,000           *              5,000          -0-%            -0-%
Malcom McGuire                          10,000           *             10,000          -0-%            -0-%
Sue Neil                                 8,000           *              8,000          -0-%            -0-%
Kevin O'Hara                             8,000           *              8,000          -0-%            -0-%
Olson Jeweler                            5,000           *              5,000          -0-%            -0-%
Bettye Oustz                             8,000           *              8,000          -0-%            -0-%
Angelo Palmisano                         5,000           *              5,000          -0-%            -0-%
Linda Chadwick                           5,000           *              5,000          -0-%            -0-%
Carol Polevoy                            8,000           *              8,000          -0-%            -0-%
Philip Wong                              8,000           *              8,000          -0-%            -0-%
Neil Cox                                 8,000           *              8,000          -0-%            -0-%
Richard Blundell                        10,000           *             10,000          -0-%            -0-%
Ken Heng                                10,000           *             10,000          -0-%            -0-%
Donna Lutsky                             5,000           *              5,000          -0-%            -0-%
Jay Lutsky                               5,000           *              5,000          -0-%            -0-%
Tanna Sessions                           5,000           *              5,000          -0-%            -0-%
Dean Sessions                            5,000           *              5,000          -0-%            -0-%
Patsy Sessions                           5,000           *              5,000          -0-%            -0-%
Michelle Brown                           5,000           *              5,000          -0-%            -0-%
James John                               8,000           *              8,000          -0-%            -0-%
Arden Amos                              10,000           *             10,000          -0-%            -0-%
Robert Sessions                          5,000           *              5,000          -0-%            -0-%
Robert Sonfield                         10,000           *             10,000          -0-%            -0-%
Margot Krimmel                          10,000           *             10,000          -0-%            -0-%
Bonnie Carol                            10,000           *             10,000          -0-%            -0-%
Max Krimmel                             10,000           *             10,000          -0-%            -0-%
Renegade Consulting (3)                100,000           *            100,000          -0-%            -0-%
Joel Pensley                           775,000        2.5%            775,000          -0-%            -0-%
Maurice Harroch                        200,000           *            200,000          -0-%            -0-%
Automotive United Group, Inc.          466,667        1.3%            466,667          -0-%            -0-%
Flo Weinberg, Inc. (4)                 215,969           *            215,969          -0-%            -0-%
DDK and Company LLC (5)                500,000        1.5%            500,000          -0-%            -0-%
Michael Sorrentino                     500,000        1.4%            500,000          -0-%            -0-%
Michael L. Metter (6)               14,147,636       30.5%          1,665,000         25.8%           22.9%
Steven Moskowitz (7)                15,285,969       32.9%          2,803,333         25.8%           22.9%
Thomas Monahan (8)                     100,000           *            100,000          -0-%            -0-%
Frank Lazauskas (9)                 15,812,636       34.1%          3,330,000         25.8%           22.9%
A&N Enterprises LLC                    310,000           *            310,000          -0-%            -0-%
Robert J. Miller                       100,000           *            100,000          -0-%            -0-%
Reed Smith LLC                         100,000           *            100,000          -0-%            -0-%
Ahava Investments Inc.                 500,000        1.4%            500,000          -0-%            -0-%
Rubin Family Irrevocable             7,377,667       21.4%          3,391,868         10.9%            9.4%
 Stock Trust (10)
D.L. Investments, Inc.               1,665,000        4.7%          1,665,000          -0-%            -0-%
Touchdown Capital Inc.                 250,000           *            250,000          -0-%            -0-%
Irwin Pearl                             32,500           *             32,500          -0-%            -0-%
Patti DeMatteo                          32,500           *             32,500          -0-%            -0-%
Eliot F. Bloom                          10,000           *             10,000          -0-%            -0-%


(1)  Applicable  percentage  ownership is based on  33,877,636  shares of common
stock outstanding as of February 24, 2005, together with securities  exercisable
or convertible  into shares of common stock within 60 days of February 24, 2005.
Beneficial  ownership  is  determined  in  accordance  with  the  rules  of  the
Securities and Exchange  Commission and generally  includes voting or investment
power with  respect to  securities.  Shares of common  stock that are  currently
exercisable or exercisable  within 60 days of February 24, 2005 are deemed to be
beneficially  owned by the person  holding  such  securities  for the purpose of
computing  the  percentage  of ownership of such person,  but are not treated as
outstanding  for the purpose of computing the percentage  ownership of any other
person.


                                       27


(2) Assumes that all securities registered will be sold.

(3) Joel  Pensley  has voting  and  investment  power  over the  shares  held by
Renegade Consulting, Inc.

(4)  Flo  Weinberg,   Inc.  is  a  wholly-owned  subsidiary  of  RM  Enterprises
International,  Inc, which owns 36.5% of the common stock of Spongetech. Michael
Metter,  Steven  Moskowitz  and Frank  Lazauskas,  the board of  directors of RM
Enterprises International, hold voting and investment power over the shares held
by Flo Weinberg.

(5)  Automotive  United  Group,  Inc.  is  majority  owned by The  Rubin  Family
Irrevocable  Stock Trust.  The trustees of The Rubin  Family  Irrevocable  Stock
Trust are Majorie Rubin and Robert Shulman, CPA

(6) Michael Metter is the President and a director of Spongetech.

(7) Steven Moskowitz is the Secretary and a director of Spongetech.

(8) Tom Monahan is the Chief Financial Officer of Spongetech.

(9) Frank Lazauskas is a director of Spongetech.
(10) The Rubin  Family  Irrevocable  Trust  owns  21.1% of the  common  stock of
Spongetech. The trustees of The Rubin Family Irrevocable Stock Trust are Majorie
Rubin and Robert Shulman, CPA


                         SHARES ELIGIBLE FOR FUTURE SALE

         On the date of the prospectus,  6,294,000  shares of common stock owned
by our  stockholders,  will be freely  tradable  without  restriction  under the
Securities  Act. None of these shares are held by our  "affiliates" as that term
is defined in Rule 144 under the Securities Act. We have outstanding  33,952,636
shares of our common stock.

         SALE  OF  RESTRICTED  SHARES.  Shares  of  our  common  stock  held  by
affiliates  will be eligible for sale in the public  market,  subject to certain
volume  limitations and the expiration of applicable  holding periods under Rule
144 of the  Securities  Act.  In  general,  under  Rule  144,  persons  who have
beneficially  owned restricted shares for at least one year are entitled to sell
within any  three-month  period  the number of shares  which does not exceed the
greater of 1% of the number of shares of common  stock then  outstanding  (which
will equal approximately 332,776 shares) or the average weekly trading volume of
the common  stock during the four  calendar  weeks  preceding  the date on which
notice of such sale was files under Form 144 with the SEC.  Sales under Rule 144
are  also  subject  to  manner  of  sale  and  notice  requirements  and  to the
availability of current public information about us. Under Rule 144(k), a person
who has not been one of our  affiliates  at any time  during  the  three  months
preceding a sale, and who has beneficially  owned the shares proposed to be sold
for at least two years, may resell the shares of common stock without  complying
with the  manner  of sale,  public  information,  volume  limitation  or  notice
requirements of Rule 144.

         We can offer no assurance  that an active  public  market in our shares
will  develop.  Future  sales of  substantial  amounts of our shares  (including
shares issued upon exercise of  outstanding  options) in the public market could
adversely affect market prices prevailing from time to time and could impair our
ability to raise capital through the sale of our equity securities.


                              PLAN OF DISTRIBUTION

SHARES TO BE SOLD BY US

         We are offering to sell a minimum of  2,000,000  units and a maximum of
8,000,000  units at a price of $0.25 per unit.  The units will be offered to the
public on a "best-efforts, all-or-none" basis as to the minimum number of shares
and on a "best efforts" basis as to the remaining shares. There is no commitment
on the part of any person to  purchase  and pay for any  shares.  Our  officers,


                                       28


directors  and/or  employees will be offering the shares for sale, but they will
receive no  compensation  for their  efforts in making any such offers or sales.
Our  officers,  directors  and employees may only make sales if they can rely on
the exemption provided by Rule 3a4-1 under the Securities  Exchange Act of 1934,
which  permits  such  persons to sell  securities  under  certain  circumstances
without registration as a securities broker.  Currently,  Michael L. Metter, our
President and Chief Executive Officer, and Steven Moskowitz, our Secretary, will
offer the  securities  on behalf of  Spongetech  Delivery  Systems.  We may also
engage  registered  broker-dealers  to offer and sell the units.  We may pay any
such  registered  persons who make such sales a  commission  of up to 10% of the
sale  price  of  each  unit  sold,   and  provide  the   registered   persons  a
non-accountable  expense  allowance  of up to 3% of the sale  price of each unit
sold.  We have not  entered  into any  underwriting  agreement,  arrangement  or
understanding for the sale of the units being offered.  In the event we retain a
broker  who may be deemed an  underwriter,  we will  file an  amendment  to this
registration  statement  with  the  Securities  and  Exchange  Commission.  This
offering is intended to be made solely by the  delivery of this  Prospectus  and
the accompanying subscription application to prospective investors.

         Prior to this  offering  there has been no public market for our common
stock.  The  offering  price of the shares was  determined  by us based upon our
assessment of our value  compared to others in our market,  taking into account,
among other matters, the following:

      o     the relatively early stage of our development  compared to others in
            similar industries;

      o     the limited capital available to us through this offering or through
            other sources;

      o     our  ability to expand and  develop  our  operations  based upon the
            capital provided by this offering;

      o     our  potential  value  if we  are  successful  in  implementing  our
            business plan;

      o     a multiple of our revenues; and

      o     the general market for publicly traded securities.

         The exercise price of the redeemable  class A warrants was based solely
         on our arbitrary assessment of a premium over the offering price of the
         unit which we believe will provide some value to the redeemable class A
         warrant.  There  can be no  assurance  that  they will in fact have any
         value.  The offering  price of the units and the exercise  price of the
         class A warrants bears no  relationship  to any recognized  criteria of
         value,  nor is it  necessarily  indicative  of the market price for the
         units, common stock or redeemable class A warrants after this offering.

         After the registration  statement of which this prospectus forms a part
has been declared effective, we will provide to each prospective investor a copy
of the final prospectus  relating to his offering which includes an agreement to
purchase units. In order to purchase the units, the subscription  application in
the form  attached to the  prospectus  and a check made payable to  "Continental
Stock Transfer & Trust Company as Escrow Agent for Spongetech  Delivery Systems,
Inc." should be completed and forwarded to us.  Receipt by us of a  subscription
agreement  and/or  deposit with the escrow  agent of payment for the  subscribed
units shall not constitute acceptance of a subscription. We reserve the fight to
withdraw,  cancel or modify the offering hereby and to reject  subscriptions  in
whole or in part, for any reason.

         The  proceeds  received  under this  offering  will be  deposited in an
on-interest  bearing  account with Olde Monmouth Stock Transfer Co., Inc. In the
event  that  less  than the  minimum  gross  proceeds  from the sale of at least
2,000,000  units being offered are received  within 60 days from the date hereof
(with an allowable  additional 30-day  extension),  we will cancel this offering
and all proceeds  received will be promptly  refunded to purchasers  without any
interest thereon.

         Certificates representing your securities will not be issued until such
times as good funds related to the purchase of the units by such subscribers are
released form the escrow  account to us by the escrow agent.  Until such time as
certificates  are  issued  to  the  subscribers,  the  subscribers  will  not be
considered shareholders of Spongetech Delivery Systems.

         Subscribers  have no right to a return of their  subscription  payments
held in the  escrow  account  until we decide  not to accept  such  subscription
payment.


                                       29


SHARES TO BE SOLD BY THE SELLING STOCKHOLDERS

            This  prospectus  also  relates  to the  resale of up to  17,259,344
additional  shares that are held by certain selling  stockholders  identified in
this prospectus. There is currently no public market for the Spongetech Delivery
Systems'  securities.  Until such time as a market price for our common stock is
quoted on the OTC  Bulletin  Board,  the  selling  shareholders  will sell their
shares at a price of $0.25 per share. Thereafter,  they may sell their shares in
public or private  transactions,  at  prevailing  market  prices or at privately
negotiated  prices. We will not receive any proceeds from the sale of the shares
of common stock by the selling shareholders.

            We will pay all expenses of registration incurred in connection with
this offering,  but the selling stockholders will pay all brokerage  commissions
and other similar expenses incurred by them.

            The  distribution  of the shares by the selling  stockholders is not
subject to any underwriting  agreement.  We expect that the selling stockholders
will sell their shares through customary brokerage  channels,  in private sales,
or in transactions under Rule 144 under the Securities Act.

            The selling stockholders,  our placement agent and other brokers and
dealers  through  whom  sales  of  the  shares  are  made  may be  deemed  to be
"underwriters"  within the meaning of the Securities Act, and the commissions or
discounts  and other  compensation  paid to those  persons  could be regarded as
underwriters compensation.

            From time to time,  the  selling  stockholders  may  engage in short
sales, short sales against the box, puts and calls and other transactions in our
common  shares,  and will be able to sell and deliver  the shares in  connection
with those  transactions  or in  settlement of  securities  loans.  In effecting
sales,  brokers and dealers engaged by the selling  stockholders may arrange for
other brokers or dealers to participate  in those sales.  Brokers or dealers may
receive commissions or discounts from the selling  stockholders (or, if any such
broker  dealer  acts as  agent  for the  purchaser  of  those  shares,  from the
purchaser) in amounts to be  negotiated  (which are not expected to exceed those
customary in the types of transactions involved).  Brokers and dealers may agree
with  the  selling  stockholder  to  sell a  specified  number  of  shares  at a
stipulated  price per share and,  to the extent  those  brokers  and dealers are
unable  to do so  acting as agent for a  selling  stockholder,  to  purchase  as
principal any unsold  shares at the price  required to fulfill the broker dealer
commitment to a selling stockholder.

            At the time a particular  offer of the shares is made, to the extent
it is required,  we will  distribute a supplement to this  prospectus  that will
identify  and set forth the  aggregate  amount of shares  being  offered and the
terms of the offering. A selling stockholder may sell shares at any price. Sales
of the shares at less than  market  price may  depress  the market  price of our
common stock.  Subject to applicable  securities  laws, the selling  stockholder
will  generally  not be restricted as to the number of shares that they may sell
at any one time, and it is possible that a significant number of shares could be
resold at the same time.

            The selling  stockholders and any other person  participating in the
distribution of the shares will also be subject to applicable  provisions of the
Securities  Exchange Act of 1934, as amended (the "Exchange Act"), and the rules
and regulations promulgated under it, including, without limitation,  Regulation
M,  which may  limit the  timing  of  purchases  and sales of the  shares by the
selling  stockholder  and any other  person.  Furthermore,  Regulation  M of the
Exchange Act may restrict the ability of any person engaged in the  distribution
of the  shares  to  engage  in  market-making  activities  with  respect  to the
particular  shares being  distributed  for a period of up to five  business days
prior to the commencement of the  distribution.  All of the foregoing may affect
the  marketability  of the  shares  and the  ability  of any person or entity to
engage in market-making activities with respect to the shares.

            To comply with certain states  securities  laws, if applicable,  the
shares may be sold in those  jurisdictions  only through  registered or licensed
brokers  or  dealers.  In certain  states  the  shares may not be sold  unless a
selling stockholder meets the applicable state notice and filing requirements.


                                       30


                 INDEMNIFICATION FOR SECURITIES ACT LIABILITIES

         Section  102(b)(7) of the Delaware  General  Corporation  Law, which we
refer to as the "DGCL," permits a provision in the certificate of  incorporation
of each corporation organized under the DGCL eliminating or limiting,  with some
exceptions,  the  personal  liability  of a director to the  corporation  or its
stockholders  for  monetary  damages for some  breaches of fiduciary  duty.  Our
Certificate of Incorporation  eliminates the personal  liability of directors to
the fullest extent permitted by the DGCL.

         Section  145 of the  DGCL,  which  we  refer  to as  "Section  145," in
summary,  empowers a Delaware  corporation  to  indemnify,  within  limits,  its
officers, directors, employees and agents against expenses (including attorneys'
fees),  judgments,  fines and amounts paid in settlement  that they actually and
reasonably incur in connection with any suit or proceeding,  other than by or on
behalf  of the  corporation,  if  they  acted  in  good  faith  and in a  manner
reasonably  believed  to be in, or not  opposed  to,  the best  interest  of the
corporation  and,  with  respect  to a  criminal  action or  proceeding,  had no
reasonable cause to believe their conduct was unlawful.

         With respect to any action by or on behalf of the corporation,  Section
145 permits a corporation  to indemnify its officers,  directors,  employees and
agents against expenses (including attorneys' fees) they actually and reasonably
incur in  connection  with the  defense  or  settlement  of the  action or suit,
provided  that person meets the standard of conduct  described in the  preceding
paragraph.  No  indemnification is permitted,  however,  in respect of any claim
where that person has been found liable to the corporation,  unless the Court of
Chancery  or  court  in which  the  action  or suit  was  brought  approves  the
indemnification and determines that the person is fairly and reasonably entitled
to be indemnified.

         As  permitted by the DGCL,  our bylaws  provide that we are required to
indemnify our directors and officers,  consultants  and employees to the fullest
extent permitted by the DGCL, Subject to certain very limited exceptions, we are
required to advance expenses, as incurred, in connection with a legal proceeding
to the fullest  extent  permitted  by the DGCL,  subject to certain very limited
exceptions.  The  rights  conferred  in our bylaws  are not  exclusive.  We have
obtained directors' and officers' liability insurance.

         Insofar as indemnification for liabilities under the Securities Act may
be permitted to our directors,  officers and controlling persons pursuant to the
provisions  described  above,  or  otherwise,  we have been  advised that in the
opinion of the  Securities  and  Exchange  Commission  such  indemnification  is
against  public  policy as expressed in the  Securities  Act and is,  therefore,
unenforceable.  In the  event  that a claim  for  indemnification  against  such
liabilities  (other than the  payment by us of expenses  incurred or paid by our
director, officer or controlling person in the successful defense of any action,
suit or proceeding) is asserted by such director,  officer or controlling person
in connection  with the  securities  being  registered,  we will,  unless in the
opinion of our  counsel  the matter as been  settled by  controlling  precedent,
submit  to a  court  of  appropriate  jurisdiction  the  question  whether  such
indemnification  by it is against  public policy as expressed in the  Securities
Act and will be governed by the final adjudication of such issue.

         Insofar as indemnification for liabilities arising under the Securities
Act of 1933 may be permitted to directors,  officers or persons  controlling  us
pursuant to the foregoing provisions, or otherwise, we have been advised that in
the opinion of the Securities and Exchange  Commission,  such indemnification is
against  public  policy  as  expressed  in the  Securities  Act of 1933  and is,
therefore, unenforceable.

                                  LEGAL MATTERS
 
         The validity of the common stock offered hereby will be passed upon for
Spongetech  Delivery  Systems,  Inc. by Sichenzia Ross Friedman Ference LLP, New
York, New York.
 
                                     EXPERTS

         Spongetech  Delivery  Systems'  financial  statements as of and for the
years ended May 31, 2004 and 2003,  and the interim  period  ended  November 30,
2004,  included in this prospectus,  have been audited by Drakeford & Drakeford,
LLC,  independent  registered  public  accountants,  as stated  in their  report
appearing  herein and are so included herein in reliance upon the report of such
firm given upon their authority as experts in accounting and auditing.


                                       31


                             ADDITIONAL INFORMATION

         We have not  previously  been  required  to comply  with the  reporting
requirements  of the  Securities  Exchange  Act.  We have  filed  with the SEC a
registration  statement on Form SB-2 to register the securities  offered by this
prospectus.  The  prospectus  is part of the  registration  statement,  and,  as
permitted by the SEC's  rules,  does not contain all of the  information  in the
registration  statement.  For  future  information  about us and the  securities
offered under this prospectus,  you may refer to the registration  statement and
to the exhibits filed as a part of the registration statement.

         In addition,  after the effective date of this  prospectus,  we will be
required to file annual,  quarterly,  and current reports,  or other information
with the SEC as provided by the  Securities  Exchange Act. You may read and copy
any  reports,  statements  or  other  information  we file at the  SEC's  public
reference  facility  maintained by the SEC at Judiciary  Plaza,  Room 1024,  450
Fifth Street,  N.W.,  Washington,  D.C.  20549.  You can request copies of these
documents, upon payment of a duplicating fee, by writing to the SEC. Please call
the SEC at 1-800-SEC-0330 for further information on the operation of the public
reference room. Our SEC filings are also available to the public through the SEC
Internet site at http\\www.sec.gov.



                                       32



                          INDEX TO FINANCIAL STATEMENTS


Part 1 - Financial Information

                                                                            Page
                                                                            ----
Item 1 - Financial Statements

      Report of Independent Auditors

      Balance Sheets as of November 30, 2004 (unaudited) and May 31, 2004    F-3

      Statements of Operations for the six months ended November 30, 2004 
          and 2003 (unaudited) and May 31, 2004 and 2003                     F-4


      Statements of Changes in Stockholders' Equity for the six months 
          ended November 30, 2004 (unaudited) and years ended May 31, 
          2004 and 2003                                                      F-5

      Statements of Cash Flows for the six months ended November 30, 
          2004 and 2003 (unaudited) and May 31, 2004 and 2003                F-6


      Notes to Financial Statements                                   F-7 - F-12




                                       F-1


                           DRAKEFORD & DRAKEFORD, LLC

                          CERTIFIED PUBLIC ACCOUNTANTS

                           A LIMITED LIABILITY COMPANY



REPORT OF INDEPENDENT ACCOUNTANTS


To the Shareholders and Directors of SPONGETECH DELIVERY SYSTEMS, INC.


We have audited the balance sheet of SPONGETECH DELIVERY SYSTEMS, INC. as of May
31,2004, and the related statements of operations, changes in stockholders'
equity (deficiency), and cash flows for the years ended May 31, 2004 and 2003.
These financial statements are the responsibility of the Company's management.
Our responsibility is to express an opinion on these financial statements based
on our audits.

We conducted our audits in accordance with auditing standards generally accepted
in the United States of America. Those standards require that we plan and
perform the audit to obtain reasonable assurance about whether the financial
statements are free of material misstatement. An audit includes examining, on a
test basis, evidence supporting the amounts and disclosures in the financial
statements. An audit also includes assessing the accounting principles used and
significant estimates made by management, as well as evaluating the overall
financial statement presentation. We believe that our audits provide a
reasonable basis for our opinion.

In our opinion, the consolidated financial statements referred to above present
fairly, in all material respects, the financial position of SPONGETECH DELIVERY
SYSTEMS, INC., as of May 31, 2004 and 2003, and the results of its operations
and its cash flows for the two years then ended, in conformity with accounting
principles generally accepted in the United States of America.

The accompanying financial statements have been prepared assuming that
SPONGETECH DELIVERY SYSTEMS, INC. will continue as a going concern. As more
fully described in Note 1, the company has incurred operating losses since the
date of organization and requires additional capital to continue operations.
These conditions raise substantial doubt about the company's ability to continue
as a going concern. Management's plans as to these matters are described in Note
1. The financial statements do not include any adjustments to reflect the
possible effects on the recoverability and classification of assets or the
amounts and classifications of liabilities that may result from the possible
inability of SPONGETECH DELIVERY SYSTEMS, INC. to continue as a going concern.



S/Drakeford & Drakeford, LLC

January 15, 2005

                                       F-2



                        SPONGETECH DELIVERY SYSTEMS, INC.

                                 BALANCE SHEETS


                                                   November 30,        May 31,
                                                      2004              2004
                                                   -----------      -----------
                                                   (unaudited)
ASSETS
Current Assets
   Cash                                            $        20      $        50
   Inventories                                             444              444
                                                   -----------      -----------
         Total current assets                              464              494

Property and equipment                                  30,689           32,831

                                                   -----------      -----------
Total assets                                       $    31,153      $    33,325
                                                   ===========      ===========

               LIABILITIES AND SHAREHOLDERS' EQUITY (DEFICIENCY)

Current Liabilities
   Accounts payable and
     accrued expenses                              $   122,516      $   122,516
   Accrued compensation                              1,804,500        1,789,500
   Income taxes payable                                  1,600            1,600
                                                   -----------      -----------
   Total current liabilities                         1,928,616        1,913,616

   Total long-term liabilities                               0                0
                                                   -----------      -----------
Total liabilities                                    1,928,616        1,913,616
                                                   -----------      -----------
Shareholders' Equity (Deficiency)
   Common stock, $.001 par value;
     Authorized 50,000,000 shares;
     issued and outstanding 18,985,000
     and 18,985,000 shares as of
     November 30, 2004 and May 31,
     2004, respectively                                 18,985           18,985
   Preferred stock $.001 par value;
     Authorized 5,000,000 shares;
     no shares issued and outstanding                        0                0
   Additional paid-in capital                          248,948          248,948
   Common stock subscribed                             526,814          526,814
   Deficit                                          (2,692,210)      (2,675,038)
                                                   -----------      -----------

 Total shareholders' equity (deficiency)            (1,897,463)      (1,880,291)
                                                   -----------      -----------
Total liabilities and shareholders'
            equity (deficiency)                    $    31,153      $    33,325
                                                   ===========      ===========


 See Independent Auditors' Report and notes to financial statements.


                                       F-3


                        SPONGETECH DELIVERY SYSTEMS, INC.
                            STATEMENTS OF OPERATIONS



                                      For the                         For the
                                  Six Months Ended                   year ended
                                    November 30,                       May 31,
                            ----------------------------    ----------------------------
                                2004            2003            2004            2003
                            ------------    ------------    ------------    ------------
                             (unaudited)     (unaudited)

                                                                         
Sales                       $          0    $      2,123    $      1,858    $    342,019

Cost of goods sold                     0           5,136           1,600         299,617
                            ------------    ------------    ------------    ------------
Gross profit (loss)                    0          (3,013)            258          42,402
                            ------------    ------------    ------------    ------------

Operating expenses
  Selling                              0          25,052          39,535          55,261
  General and
   Administrative
   expenses                       15,030          25,462       2,007,953         241,428
  Depreciation expense             2,142           2,750           4,284          10,830
                            ------------    ------------    ------------    ------------

Total operating expenses          17,172          53,264       2,051,772         307,519
                            ------------    ------------    ------------    ------------

Loss before provision
 for income taxes                (17,172)        (56,277)     (2,051,514)       (265,117)

Other income and expenses
  Interest expense                                     0           5,012             400
                            ------------    ------------    ------------    ------------
Total income and
  expense                                              0           5,012             400

Net loss                    $    (17,172)   $    (56,277)   $ (2,056,526)   $   (265,517)
                            ============    ============    ============    ============

Basic and diluted (loss) 
   per common stock

Net loss per share -
   basic and diluted        $       (.01)   $       (.01)   $       (.01)   $       (.01)
                            ============    ============    ============    ============

Weighted average common
   shares outstanding         18,985,000      18,985,000      18,985,000      18,985,000
                            ============    ============    ============    ============



  See Independent Auditors' Report and notes to financial statements.


                                       F-4


                        SPONGETECH DELIVERY SYSTEMS, INC.
                  STATEMENTS OF CHANGES IN SHAREHOLDERS' EQUITY
                                  (DEFICIENCY)
             For The Six Months Ended November 30, 2004 (Unaudited)
                      and Years Ended May 31, 2004 and 2003



                                                                                           Total
                                         Additional                   Common           Shareholders'
                            Number of      Capital      Paid-In       Stock                Equity
                             Shares        Stock        Capital     Subscribed     Deficit      (Deficiency)
                          -----------   -----------   -----------    ---------   -----------    -----------
                                                                                       
Balance -
June 1,2000                12,000,000   $    12,000   $        --    $      --   $   (52,200)   $   (40,200)

Net loss for year
 ended May 31, 2001                --            --            --                   (198,318)      (198,318)
                          -----------   -----------   -----------    ---------   -----------    -----------
                           12,000,000        12,000            --           --      (250,518)      (238,518)

Contributions                      --            --       105,100                         --        105,100
                          -----------   -----------   -----------    ---------   -----------    -----------

Balance -
 May 31, 2001              12,000,000        12,000       105,100           --      (250,518)      (133,418)

Contributions                      --            --        86,943                         --         86,943

Net loss for year ended
   May 31, 2002                    --            --            --                   (102,477)      (102,477)
                          -----------   -----------   -----------    ---------   -----------    -----------
                           12,000,000        12,000       192,043           --      (352,995)      (148,952)

Issuance of
  common stock              6,985,000         6,985        (1,595)                        --          5,390
Value of services
   contributed by
   officers                        --            --        58,500                         --         58,500
Net loss for the
 year ended
 May 31, 2003                                                                       (265,517)      (265,517)
                          -----------   -----------   -----------    ---------   -----------    -----------
Balance -
May 31, 2003               18,985,000   $    18,985   $   248,948           --   $  (618,512)   $  (350,579)

Common stock subscribed                                                526,814                      526,814

Net loss for the
 year ended
 May 31, 2004                                                                     (2,056,526)    (2,056,526)
                          -----------   -----------   -----------    ---------   -----------    -----------
Balance -
May 31, 2004               18,985,000   $    18,985   $   248,948    $ 526,814   $(2,675,038)   $(1,880,291)

Unaudited
Net loss for
The six
Months ended
 November 30, 2004                                                                   (17,172)       (17,172)
                          -----------   -----------   -----------    ---------   -----------    -----------
Balance-Unaudited
November 30, 2004          18,985,000   $    18,985   $   248,948    $ 526,814   $(2,692,210)   $ 1,897,463)
                          ===========   ===========   ===========    =========   ===========    ===========


   See Independent Auditors' Report and notes to financial statements.

                                       F-5


                        SPONGETECH DELIVERY SYSTEMS, INC.
                            STATEMENTS OF CASH FLOWS



                                             For the six
                                             Months Ended                    For the
                                             November 30,                Year Ended May 31,
                                      --------------------------    --------------------------
                                          2004           2003           2004           2003
                                      -----------    -----------    -----------    -----------
                                      (unaudited)    (unaudited)
                                                                                
Operating Activities:
 Net loss                             $   (17,172)   $   (56,277)   $(2,056,526)   $  (265,517)
 Adjustments to reconcile net loss
 to net cash provided by (used in)
 operating activities
 Value of contributed officer
   compensation                                 0              0              0         39,000
 Bad debts                                      0              0              0         13,909
 Depreciation                               2,142          2,750          4,284         10,830
 Common stock subscribed in release
   of company debt                              0              0        526,814              0

 Changes in operating assets and
   liabilities
   Accounts receivable                          0              0         15,003         (1,395)
   Inventories                                  0            852            852         48,061
   Prepaid expense and other
     current assets                             0              0              0            118
   Accounts payable and accrued
     expenses                                   0         (1,836)      (121,404)        94,383
   Accrued compensation                    15,000              0      1,789,500              0
   Income taxes payable                         0              0              0            400
   Due to related parties                       0         15,871       (159,578)        30,949
                                      -----------    -----------    -----------    -----------

Net cash provided by (used in)
 operating activities                         (30)       (38,640)        (1,055)       (29,262)
                                      -----------    -----------    -----------    -----------
Investing Activities:
 Acquisition of property and
  equipment                                     0           (728)             0         (7,700)
                                      -----------    -----------    -----------    -----------

Net cash used in investing
 activities                                     0           (728)             0         (7,700)
                                      -----------    -----------    -----------    -----------

Financing Activities:
Proceeds from factor, net                       0         13,608              0        (13,608)
Proceeds of note payable - related
  party                                         0         25,000              0         51,500
                                      -----------    -----------    -----------    -----------
Net cash provided by
  financing activities                          0         38,608              0         37,892
                                      -----------    -----------    -----------    -----------

Net increase (decrease) in cash               (30)          (760)        (1,055)           930

Cash - beginning                               50          1,105          1,105            175
                                      -----------    -----------    -----------    -----------
 Cash - end                           $        20    $       345    $        50    $     1,105
                                      ===========    ===========    ===========    ===========

Supplemental Information
   Interest paid                      $         0    $       500    $       110    $       110
   Income taxes paid                  $         0    $         0    $         0    $         0

Noncash Transactions:
Parent company debt contributed
  to additional paid-in capital       $         0    $         0    $    10,000    $         0
Issuance of common stock              $         0    $     5,390    $         0    $         0
Common stock subscribed               $         0    $         0    $   526,814    $         0


  See Independent Auditors' Report and notes to financial statement.

                                       F-6


                        SPONGETECH DELIVERY SYSTEMS, INC.

                          NOTES TO FINANCIAL STATEMENTS


1 - Summary of Significant Accounting Policies

     Nature of Operations

     Spongetech Delivery Systems, Inc. (the "Company") was formed on June 18,
1999, as Romantic Scents, Inc. On June 12, 2001, the Company changed its name to
RSI Enterprises, Inc., and, on October 2, 2002, changed its name to Spongetech
International Ltd. ("SIL"). On July 15, 2002, the Company was acquired by
Spongetech Delivery Systems, Inc. ("SDS") (formerly Nexgen Acquisitions VIII,
Inc.). The transaction was accounted for as a reverse acquisition using the
purchase method of accounting, whereby the shareholder of SIL retained
approximately 63% of the Company's outstanding common stock. On December 16,
2002, SIL changed its domicile to Delaware by merging with and into Spongetech
Sub, Inc. ("SUB"). SUB's parent, Spongetech Delivery Systems, Inc. then merged
with and into SUB so that SUB became the surviving corporation, and changed its
name to Spongetech Delivery Systems, Inc.

     The Company distributes a line of hydrophilic polyurethane sponge cleaning
and waxing products.

     Basis of Presentation / Going Concern

     The financial statements have been prepared for purposes of registration
with the Securities and Exchange Commission ("SEC"), and have been prepared in
conformity with accounting principles generally accepted in the United States of
America, which contemplates continuation of the Company as a going concern.
However, the Company has sustained substantial operating losses in recent years,
current liabilities exceed current assets, and total liabilities exceed total
assets. These factors raise substantial doubt about the Company's ability to
continue as a going concern. The recovery of assets and continuation of future
operations are dependent upon the Company's ability to obtain additional debt or
equity financing and its ability to generate revenues sufficient to continue
pursuing its business purposes. The Company is actively pursuing financing to
fund future operations.

     Interim Financial Information (Unaudited)

     The interim financial statements of the Company as of November 30, 2004 and
for the six months ended November 30, 2004 and 2003, included herein, have been
prepared by the Company, without audit, pursuant to the rules and regulations of
the SEC. The unaudited interim financial statements include all adjustments,
consisting of normal recurring adjustments, considered necessary for a fair
presentation of the results for the interim periods presented. Certain
information and footnote disclosures normally included in the financial
statements prepared in accordance with generally accepted accounting principles
have been condensed or omitted pursuant to such rules and regulations relating
to interim financial statements. In the opinion of management, the accompanying
unaudited statements reflect all adjustments necessary to present fairly the
results of its operations and its cash flows for the six months ended November
30, 2004 and 2003.


                                       F-7


1    - Summary of Significant Accounting Policies (Continued)

     Accounts Receivable

     Accounts receivable have been adjusted for all known uncollectible
accounts. At May 31, 2004 and November 30, 2004, there were no accounts
receivables.

     Inventories

     Finished products inventories are carried at cost, principally first-in,
first-out, but not in excess of market.

     Property and Equipment

     Property and equipment are carried at cost. Depreciation has been provided
using straight-line and accelerated methods over the estimated useful lives of
the assets. Repairs and maintenance are expensed as incurred, and renewals and
betterments are capitalized.

     Deferred Income Taxes

     The Company recognizes deferred income tax assets and liabilities for the
expected future income tax consequences of temporary differences between the
carrying amounts and the income tax bases of assets and liabilities and the
effect of future income tax planning strategies to reduce any deferred income
tax liability.

     Use of Estimates

     The preparation of financial statements in conformity with accounting
principles generally accepted in the United States of America requires
management to make estimates and assumptions that affect certain reported
amounts and disclosures. Accordingly, actual results could differ from those
estimates.

     Offering Costs

     Deferred offering costs incurred by the Company in connection with the
proposed registration statement will be expensed as incurred.

     Advertising Costs

     Advertising costs are expensed as incurred. For the years ended May 31,
2004 and 2003, advertising costs totaled $17,500 and $10,719, respectively.

     For the six months ended November 30, 2004 and 2003, advertising costs
totaled $0 and $17,500, respectively.

1 -  Summary of Significant Accounting Policies (Continued)

     Shipping and Handling Costs

     Shipping and handling costs are included in selling expenses. For the years
ended May 31, 2004 and 2003, shipping and handling costs totaled $0 and $21,333
respectively. For the six months ended November 30, 2004 and 2003, shipping and
handling costs totaled $ -0- and $ 0, respectively.

     Net Income (Loss) Per Share

     Per share data has been computed and presented pursuant to the provisions
of SFAS No. 128, earnings per share. Net income (loss) per common share - basic
is calculated by dividing net income (loss) by the weighted average number of
common shares outstanding during the period. Net income (loss) per common share
- diluted is calculated by dividing net income (loss) by the weighted average
number of common shares and common equivalent shares for stock options
outstanding during the period.

     Recent Accounting Pronouncements

     New accounting statements issued, and adopted by the Company, include the
following:

     In July 2001, the Financial Accounting Standards Board ("FASB") issued
Statement No. 141, "Business Combinations" ("SFAS 141"), which requires all
business combinations initiated after June 30, 2001 to be accounted for using
the purchase method of accounting. As a result, use of the pooling-of-interests

                                       F-8


method is prohibited for business combinations initiated thereafter. SFAS 141
also establishes criteria for the separate recognition of intangible assets
acquired in a business combination. The adoption of SFAS 141 did not have a
material impact on the Company's results of operations, financial position or
cash flows

     In July 2001, the FASB issued Statement No. 142, "Goodwill and Other
Intangible Assets" ("SFAS 142"), which requires that goodwill and certain other
intangible assets having indefinite lives no longer be amortized to earnings,
but instead be subject to periodic testing for impairment. Intangible assets
determined to have definitive lives will continue to be amortized over their
useful lives. This Statement is effective for the Company's 2003 fiscal year.
However, goodwill and intangible assets acquired after June 30, 2001 are subject
immediately to the non-amortization and amortization provisions of this
Statement. The adoption of SFAS 142 did not have an impact on the Company's
results of operations, financial position or cash flows.

     Recent Accounting Pronouncements (Continued)

     In August 2001, the FASB issued Statement No. 143, "Accounting for Asset
Retirement Obligations" ("SFAS 143"), which provides the accounting requirements
for retirement obligations associated with tangible long-lived assets. This
Statement requires entities to record the fair value of a liability for an asset
retirement obligation in the period in which it is incurred. This Statement is
effective for the Company's 2003 fiscal year, and early adoption is permitted.
The adoption of SFAS 143 did not have a material impact on the Company's results
of operations, financial position or cash flows.

     In October 2001, the FASB issued Statement No. 144, "Accounting for the
Impairment or Disposal of Long-Lived Assets" ("SFAS 144"), which excludes from
the definition of long-lived assets goodwill and other intangibles that are not
amortized in accordance with SFAS 142. SFAS 144 requires that long-lived assets
to be disposed of by sale be measured at the lower of carrying amount or fair
value less cost to sell, whether reported in continuing operations or in
discontinued operations. SFAS 144 also expands the reporting of discontinued
operations to include components of an entity that have been or will be disposed
of rather than limiting such discontinuance to a segment of a business. This
Statement is effective for the Company's 2003 fiscal year, and early adoption is
permitted. The adoption of SFAS 144 did not have a material impact on the
Company's results of operations, financial position or cash flows.

     In April 2002, the FASB issued SFAS No. 145, Rescission of FASB Statements
No. 4, 44 and 64, Amendment of FASB Statement No. 13, and Technical Corrections.
Among other provisions, this Statement eliminates the requirement that gains and
losses from extinguishment of debt be classified as extraordinary items. The
Company will adopt SFAS 145 in fiscal 2003, and has determined it will not
impact the Company's financial position, results of operations or cash flows.

     In July 2002, the FASB issued SFAS No. 146, Accounting for Costs Associated
with Exit or Disposal Activities. This Statement requires that a liability for a
cost associated with an exit or disposal activity be recognized when the
liability is incurred, rather than when a company commits to an exit plan as was
previously required. SFAS 146 is effective for exit or disposal activities that
are initiated after December 31, 2002. The Company will adopt SFAS 146 in fiscal
2003, and has determined it will not impact the Company's financial position,
results of operations or cash flows.

     Recent Accounting Pronouncements (Continued)

     In December 2002, the FASB issued SFAS No. 148, "Accounting for Stock-Based
Compensation-Transition and Disclosure." This statement amends SFAS No. 123,
"Accounting for Stock-Based Compensation," to provide alternative methods of
transition for a voluntary change to the fair-value-based method of accounting
for stock-based employee compensation. In addition, this statement amends the
disclosure requirements of SFAS 123 to require prominent disclosures in both
annual and interim financial statements about the method of accounting for
stock-based employee compensation and the effect of the method used on reported
results. The Company accounts for stock-based employee compensation arrangements
in accordance with the provisions of Accounting Principles Board Opinion No. 25,
"Accounting for Stock Issued to Employees," and complies with the disclosure
provisions of SFAS 123 and SFAS 148.

                                       F-9


     In November 2002, FASB Interpretation No. 45, "Guarantor's Accounting and
Disclosure Requirements for Guarantees, Including Indirect Guarantees and
Indebtedness of Others," was issued. This interpretation requires the initial
recognition and initial measurement, on a prospective basis only, to guarantees
issued or modified after December 31, 2002. Additionally, certain disclosures
requirements are effective for financial statements ending after December 15,
2002. There were no disclosures required of the Company in the 2002 financial
statements, and the Company does not believe that the adoption of this
interpretation in 2003 will have any impact on its financial statements.

     In January 2003, FASB Interpretation No. 46, "Consolidation of Variable
Interest Entities," ("VIE's") was issued. This interpretation clarifies
situations in which entities shall be subject to consolidation. This
interpretation is effective for all VIE's created after January 31, 2003. The
Company does not believe that the adoption of this interpretation will have any
impact on its financial statements.

2 -  Property and Equipment

     Property and equipment is summarized as follows:

                               Estimated
                             Useful Lives    November 30,   May 31,
                                 Years          2004         2004
                             ------------   ------------  ---------
                                            (unaudited)

     Furniture and fixtures     5 - 7        $    761      $    761
     Machinery and equipment    5 - 7          17,828        17,828
     Molds                      5              38,312        38,312
                                             --------      --------

                                               56,901        56,901

     Less:  Accumulated depreciation           26,212        24,070
                                             --------      --------

                                             $ 30,689      $ 32,831
                                             ========      ========

     Depreciation expense for the years ended May 31, 2004 and 2003 was $4,284
and $10,830, respectively. Depreciation expense for the six months ended
November 30, 2004 and 2003 was $2,142 and $2,750, respectively.

3 -  Stock Purchase Agreement

     On July 15, 2002, SDS entered into an agreement with RM Enterprises
International, Inc., a Delaware corporation, to acquire its wholly-owned
subsidiary SIL. On that date, SDS acquired all of the common stock of SIL for
12,000,000 shares of its $.001 par value common stock. The transaction was
structured as a tax free exchange and was accounted for as a reverse
acquisition, using the purchase method of accounting.

4 -  Accounts payable and accrued expenses consist of the following:

                                        November 31,        May 31,
                                            2004             2004
                                       ------------       ----------
                                       (unaudited)

 Product development                   $   86,516         $   86,516
 Advertising                               36,000             36,000
                                       ----------         ----------

   Total                               $  122,516         $  122,516
                                       ==========         ==========

 Accrued compensation                  $1,804,500         $1,789,500
                                       ==========         ==========

         See Note- 8 -Subsequent events


                                      F-10


5 -  Related Party Transactions

     The Company shares its facility with other related businesses. Expenses
incurred in the operations of the facility, including rent, telephone, and other
office expenses, were allocated to the various businesses. The allocations were
based on usage. Management believes these allocations are reasonable. See Note-8
for new location and lease arrangements.

6 - Deferred Income Taxes

     At November 30, 2004 and May 31, 2004, the Company had approximately
$2,317,733 and $2,300,561, respectively, of net operating loss carryforwards
available, which expire in various years through May 31, 2022. The significant
component of the Company's deferred tax asset as of November 30, 2004 and May
31, 2004 is as follows:

                                                 November 30,      May 31,
                                                     2004           2004
                                                 ------------   -----------
                                                 (unaudited)

Non-Current
  Net operating loss carryforwards                $2,317,733    $ 2,300,561

Valuation allowance for
  deferred tax asset                              (2,317,733)    (2,300,561)
                                                  ----------    -----------

                                                  $       --    $       --
                                                  ==========    ===========

     SFAS No. 109 requires a valuation allowance to be recorded when it is more
likely than not that some or all of the deferred tax asset will not be realized.
At November 30, 2004 and May 31, 2004, a valuation allowance for the full amount
of the net deferred tax asset was recorded.

7 - Commitments and Contingencies

     Supply and License Agreements

     In July 2001, the Company entered into a supply and requirement agreement
with Dicon Technologies ("Dicon"), a manufacturing company that has
technological know-how and patented and proprietary information relating to
hydrophilic foam materials (sponges) and their applications. The agreement
requires the Company to purchase all of their requirement from Dicon, and Dicon
grants exclusive worldwide rights to distribute the products. Minimum annual
purchase requirements are set forth in the agreement. The agreement expired June
30, 2004; however, the purchase on an as needed basis continues.

     The Company and Dicon have also entered into an exclusive license agreement
for certain molded hydrophilic foam products which the Company helped develop,
with super absorbent polymer and detergent soaps and waxes used for the cleaning
and polishing of land, sea and transportation vehicles. The term of the
agreement is for the full life of any design patent, which may be issued on the
molded sponge design.

                                      F-11


     Employment Contracts

     The Company is currently negotiating with two executives to establish
employment contracts. No terms of these negotiations have been disclosed.


8 - Subsequent Events

         Subsequent to the date of the financial statements, the company issued
an aggregate number of shares totaling $526,814 consisting of officers loans and
trade debt payables. As of May 31, 2004 and November 30, 2004, the common stock
subscribed represents these common shares.

       Also in January 2005, the company converted the accrued compensation to
10,330,000 shares of common stock. (see Note-4) The company also agreed to the
exchange of an aggregate of 60,000 shares of common stock of the corporation in
consideration for a sublease from A & N Enterprises, LLC. The new address is The
Empire State Building, 350 5th Avenue, Suite 2204, New York, New York 10118. The
lease shall be for the period December 8, 2004 through January 31, 2008.


                                      F-12



YOU SHOULD RELY ONLY ON THE INFORMATION  CONTAINED IN THIS  PROSPECTUS.  WE HAVE
NOT  AUTHORIZED  ANYONE  TO  PROVIDE  YOU WITH  INFORMATION  DIFFERENT  FROM THE
INFORMATION  CONTAINED IN THIS PROSPECTUS.  THIS DOCUMENT MAY ONLY BE USED WHERE
IT IS LEGAL TO SELL THE SECURITIES. THE INFORMATION IN THIS DOCUMENT MAY ONLY BE
ACCURATE ON THE DATE OF THIS DOCUMENT.



                       UP TO 8,000,000 UNITS CONSISTING OF
                            ONE SHARE OF COMMON STOCK
                                       AND
                         ONE REDEEMABLE CLASS A WARRANT

                                       AND

                                   17,259,344
                                    SHARES OF
                                  COMMON STOCK

                                       OF
 
                        SPONGETECH DELIVERY SYSTEMS, INC.
 

 

 
                                   PROSPECTUS
 

 
 
                The date of this prospectus is ____________, 2005



                                     PART II
 
                     INFORMATION NOT REQUIRED IN PROSPECTUS
 
ITEM 24.    INDEMNIFICATION OF DIRECTORS AND OFFICERS
 
Indemnification of directors and executive officers and limitation of liability 

         Section  102(b)(7) of the Delaware  General  Corporation  Law, which we
refer to as the "DGCL," permits a provision in the certificate of  incorporation
of each corporation organized under the DGCL eliminating or limiting,  with some
exceptions,  the  personal  liability  of a director to the  corporation  or its
stockholders  for  monetary  damages for some  breaches of fiduciary  duty.  Our
Certificate of Incorporation  eliminates the personal  liability of directors to
the fullest extent permitted by the DGCL.

         Section  145 of the  DGCL,  which  we  refer  to as  "Section  145," in
summary,  empowers a Delaware  corporation  to  indemnify,  within  limits,  its
officers, directors, employees and agents against expenses (including attorneys'
fees),  judgments,  fines and amounts paid in settlement  that they actually and
reasonably incur in connection with any suit or proceeding,  other than by or on
behalf  of the  corporation,  if  they  acted  in  good  faith  and in a  manner
reasonably  believed  to be in, or not  opposed  to,  the best  interest  of the
corporation  and,  with  respect  to a  criminal  action or  proceeding,  had no
reasonable cause to believe their conduct was unlawful.

         With respect to any action by or on behalf of the corporation,  Section
145 permits a corporation  to indemnify its officers,  directors,  employees and
agents against expenses (including attorneys' fees) they actually and reasonably
incur in  connection  with the  defense  or  settlement  of the  action or suit,
provided  that person meets the standard of conduct  described in the  preceding
paragraph.  No  indemnification is permitted,  however,  in respect of any claim
where that person has been found liable to the corporation,  unless the Court of
Chancery  or  court  in which  the  action  or suit  was  brought  approves  the
indemnification and determines that the person is fairly and reasonably entitled
to be indemnified.

         As  permitted by the DGCL,  our bylaws  provide that we are required to
indemnify our directors and officers,  consultants  and employees to the fullest
extent permitted by the DGCL, Subject to certain very limited exceptions, we are
required to advance expenses, as incurred, in connection with a legal proceeding
to the fullest  extent  permitted  by the DGCL,  subject to certain very limited
exceptions.  The  rights  conferred  in our bylaws  are not  exclusive.  We have
obtained directors' and officers' liability insurance.

         Insofar as indemnification for liabilities under the Securities Act may
be permitted to our directors,  officers and controlling persons pursuant to the
provisions  described  above,  or  otherwise,  we have been  advised that in the
opinion of the  Securities  and  Exchange  Commission  such  indemnification  is
against  public  policy as expressed in the  Securities  Act and is,  therefore,
unenforceable.  In the  event  that a claim  for  indemnification  against  such
liabilities  (other than the  payment by us of expenses  incurred or paid by our
director, officer or controlling person in the successful defense of any action,
suit or proceeding) is asserted by such director,  officer or controlling person
in connection  with the  securities  being  registered,  we will,  unless in the
opinion of our  counsel  the matter as been  settled by  controlling  precedent,
submit  to a  court  of  appropriate  jurisdiction  the  question  whether  such
indemnification  by it is against  public policy as expressed in the  Securities
Act and will be governed by the final adjudication of such issue.

         Insofar as indemnification for liabilities arising under the Securities
Act of 1933 may be permitted to directors,  officers or persons  controlling  us
pursuant to the foregoing provisions, or otherwise, we have been advised that in
the opinion of the Securities and Exchange  Commission,  such indemnification is
against  public  policy  as  expressed  in the  Securities  Act of 1933  and is,
therefore, unenforceable.

ITEM 25.    OTHER EXPENSES OF ISSUANCE AND DISTRIBUTION
 
         The  following  table  sets  forth  an  itemization  of  all  estimated
expenses,  all of  which we will  pay,  in  connection  with  the  issuance  and
distribution of the securities being registered:


                                      II-1


                    Nature of Expense                       AMOUNT
                    -----------------                     ---------
               SEC Registration fee                       $1,214.06
               Accounting fees and expenses               $  30,000*
               Legal fees and expenses                      *60,000
                                                          ---------
               Miscellaneous                              $   8,800
                                                          ---------
                       TOTAL                              $100,014.06
                                                          ===========
               * Estimated


ITEM 26.    RECENT SALES OF UNREGISTERED SECURITIES

         In January  2005,  we issued  3,330,000  shares of our common  stock to
Michael.  L. Metter, our President and Chief Executive Officer,  as compensation
for services performed on our behalf.

         In January  2005,  we issued  3,270,000  shares of our common  stock to
Steven Moskowitz,  our Secretary,  as compensation for services performed on our
behalf.

         In January 2005, we issued 100,000 shares of our common stock to Thomas
Monahan,  our Chief Financial Officer, as compensation for services performed on
our behalf.

         In January  2005,  we issued  3,330,000  shares of our common  stock to
Frank  Lazauskas,  a director  of the  Company,  as  compensation  for  services
performed on our behalf.

         In January  2005,  we issued  2,000,000  shares of our common  stock to
Robert Rubin as compensation for services performed on our behalf.

         In  January  2005,  we issued  466,667  shares of our  common  stock to
American United Global, Inc. in exchange for $70,000 in debt.

         In January  2005, we issued  500,000  shares of our common stock to DDK
and Company LLC in exchange for $66,000 of debt.

         In January  2005, we issued  215,969  shares of our common stock to Flo
Weinberg, Inc. in exchange for $36,527.25 in debt.

         In January 2005, we issued 533,333 shares of our common stock to Steven
Moskowitz in exchange for $80,000 in debt.

         In January 2005, we issued 120,000 shares of our common stock to Robert
Rubin in exchange for $18,000 in debt.

         In  January  2005,  we issued  466,667  shares  of  common  stock to RM
Enterprises International, Inc. in exchange for $70,000 in debt.

         In  January  2005,  we issued  500,000  shares of our  common  stock to
Michael Sorrentino in exchange for $75,000 in debt.

         In January  2005,  we issued  60,000  shares of our common stock to our
subleasor in consideration for our use of the premises.

         In  February  2005,  we issued  75,000  shares of our  common  stock to
Paradigm  Solutions,  Inc.  in  connection  with  a  Settlement  Agreement  with
Paradigm, dated February 15, 2005.

         All of the  foregoing  issuances  were exempt from  registration  under
Section 4(2) of the Securities Act and/or Regulation S, promulgated  pursuant to
the Securities Act. None of the purchasers who received shares under  Regulation
S are U.S.  persons  as  defined in Rule  902(k) of  Regulation  S, and no sales


                                      II-2


efforts  were  conducted  in the U.S.,  in  accordance  with Rule  903(c).  Such
purchasers  acknowledged that the securities purchased must come to rest outside
the U.S., and the  certificates  contain a legend  restricting  the sale of such
securities until the Regulation S holding period is satisfied.

ITEM 27.    EXHIBITS

3.1      Certificate of Incorporation of Nexgen VIII, Inc.(1)

3.2      Certificate  of  Amendment  of  Nexgen  VIII,  Inc.  changing  name  to
         Spongetech Delivery Systems, Inc.(1)

3.3      By-Laws of Spongetech Delivery Systems, Inc.(1)

3.4      Certificate of Incorporation of Romantic Scents, Inc. (2)

3.5      Certificate of Amendment changing name of Romantic Scents,  Inc. to RSI
         Enterprises, Inc. (2)

3.7      Certificate  of Amendment  changing  name of RSI  Enterprises,  Inc. to
         Spongetech Enterprises International, Inc. (2)

3.7      Certificate of Incorporation of Merger Sub, Inc. (2)

3.8      Merger Certificate  between Spongetech Delivery Systems and Merger Sub,
         Inc. (2)

3.9      Merger Certificate between Spongetech Enterprises  International,  Inc.
         and Merger Sub, Inc. (2)

3.10     Certificate  of  Amendment   changing  name  of  Merger  Sub,  Inc.  to
         Spongetech Delivery Systems, Inc. (2)

4.1      Specimen Certificate of Common Stock(1)

4.2      Warrant Certificate (3)

4.3      Warrant Agreement with Colebrook, Inc. and Olde Monmouth Stock Transfer
         Co., Inc. (3)

4.4      Oral Understanding with Dicon (5)

5.1      Opinion of Counsel(7)

5.2      Revised Opinion of Counsel (2)

5.3      Revised Opinion of Counsel (3)

5.4      Revised Opinion of Counsel (4)

10.1     Stock Purchase  Agreement by and among Nexgen  Acquisitions VIII, Inc.,
         RM Enterprises International, Inc. and RSI Enterprises, Inc.(1)

10.2     Stock Purchase  Agreement by and between  Spongetech  Delivery Systems,
         Inc. and Colebrook, Inc. (2)

10.3     License Agreement dated July 1, 2001 with Dicon Technologies (2)

10.4     Supply  and  Requirements  Agreement  dated  July 1,  2001  with  Dicon
         Technologies (2)

10.5     Manufacturer's  Representative  Agreement dated July 1, 2001 with Dicon
         Technologies (2)

10.6     Extension  of debt letter by Romantic  Moments,  Inc.  dated August 15,
         2002 (4)


                                      II-3


10.7     Terms of oral  understanding  with Dicon Technologies to expand license
         (5)

10.8     Factoring Agreement with Westgate (4)

10.9     Agreement with Paradigm (6)

23.1     Accountant's Consent (7)

23.2     Counsel's Consent to Use Opinion (7)

-------------
(1)  Previously filed as an exhibit to registration statement on Form SB-2 filed
     November 1, 2002

(2)  Previously filed as an exhibit to first amendment to registration statement
     on Form SB-2 filed January 13, 2003

(3)  Previously  filed  as  an  exhibit  to  second  amendment  to  registration
     statement on Form SB-2 filed April 11, 2003

(4)  Previously filed as an exhibit to third amendment to registration statement
     on Form SB-2 filed July 8, 2003

(5)  Previously  filed  as  an  exhibit  to  fourth  amendment  to  registration
     statement on Form SB-2 filed January 12, 2004

(6)  Previously filed as an exhibit to fifth amendment to registration statement
     on Form SB-2 filed March 15, 2004

(7)  Filed with this amendment


ITEM 28.    UNDERTAKINGS
 
      The undersigned Registrant hereby undertakes:

      (1) To file a  post-effective  amendment  to this  Registration  Statement
during any period in which offers or sales are being made:

            (i)  to include any Prospectus required  by  Section 10(a)(3) of the
      Securities Act;
 
            (ii) to reflect in the  Prospectus any facts or events arising after
      the  effective  date of the  Registration  Statement  (or the most  recent
      post-effective   amendment  thereof)  which,   individually,   or  in  the
      aggregate,  represent a fundamental change in the information set forth in
      the Registration Statement. Notwithstanding the foregoing, any increase or
      decrease in volume of  securities  offered (if the total  dollar  value of
      securities  offered  would not exceed that which was  registered)  and any
      deviation from the low or high end of the estimated maximum offering range
      may be  reflected  in the form of  prospectus  filed  with the  Commission
      pursuant  to Rule  424(b)  ((S)230.424(b)  of  this  Chapter)  if,  in the
      aggregate,  the changes in volume and price  represent  no more than a 20%
      change  in  the  maximum  aggregate   offering  price  set  forth  in  the
      "Calculation  of  Registration  Fee" table in the  effective  Registration
      Statement; and
 
            (iii) to include any material  information  with respect to the plan
      of distribution not previously disclosed in the Registration  Statement of
      any material change to such information in the Registration Statement.
 
      (2) To remove from registration by means of a post-effective amendment any
of the securities  being  registered  which remain unsold at the  termination of
this offering.
 
      (3)  To  provide  to the  Underwriters  at the  closing  specified  in the
underwriting agreement certificates in such denominations and registered in such
names  as  required  by the  Underwriter  to  permit  prompt  delivery  to  each
purchaser.
 
                                      II-4


      (4)  That,  for  the  purpose  of  determining  any  liability  under  the
Securities Act, each such  post-effective  amendment shall be deemed to be a new
Registration  Statement  relating to the securities  offered  therein,  and this
offering of such  securities at that time shall be deemed to be the initial bona
fide offering thereof.
 
      (5) That,  insofar as  indemnification  for  liabilities  arising from the
Securities Act may be permitted to directors,  officers, and controlling persons
of the  Registrant  pursuant to the  foregoing  provisions,  or  otherwise,  the
Registrant  has  been  advised  that  in  the  opinion  of the  Commission  such
indemnification  is against public policy as expressed in the Securities Act and
is,  therefore,  unenforceable.  In the event  that a claim for  indemnification
against such  liabilities  (other than the payment by the Registrant of expenses
incurred or paid by a director,  officer or controlling person of the Registrant
in the successful defense of any action, suit or proceeding) is asserted by such
director,  officer or controlling person in connection with the securities being
registered, the Registrant will, unless in the opinion of its counsel the matter
has been  settled by  controlling  precedent,  submit to a court of  appropriate
jurisdiction the question whether such  indemnification  by it is against public
policy as  expressed  in the  Securities  Act and will be  governed by the final
adjudication of such issue.
 
      (6) That, for purposes of determining  any liability  under the Securities
Act, the information  omitted from the form of Prospectus  filed as part of this
Registration  Statement  in reliance  upon Rule 430A and  contained in a form of
Prospectus  filed by the  Registrant  pursuant to Rule  424(b)(1) or (4) or Rule
497(h) under the Securities Act shall be deemed to be part of this  Registration
Statement as of the time it was declared effective.


                                      II-5


                                   SIGNATURES
 
         Pursuant to the requirements of the Act, the Company  certifies that it
has  reasonable  grounds to  believe  that it meets all of the  requirement  for
filing on Form SB-2 and has duly caused this Registration Statement to be signed
on its behalf by the undersigned,  thereunto duly  authorized,  in New York, New
York on February 25, 2005.

                                             SPONGETECH DELIVERY SERVICES, INC.


                                             By: /s/ Michael L. Metter
                                                 ---------------------
                                                 Michael L. Metter
                                                 President and Chief Executive
                                                 Officer

                                             By: /s/ Thomas Monahan   
                                                 ----------------------
                                                 Thomas Monahan
                                                 Chief Financial Officer


         In  accordance  with  the  requirements  of the  Securities  Act,  this
Registration  Statement has been signed below by the following persons on behalf
of the Company in the capacities and on the dates indicated.
 

       SIGNATURE                         TITLE                       DATE
       ---------                         -----                       ----

 /s/ Michael L. Metter          President and Director         February 25, 2005
----------------------
Michael L Metter

 /s/ Steven Moskowitz           Secretary and Director         February 25, 2005
----------------------
Steven Moskowitz

 /s/ Frank Lazauskas            Director                       February 25, 2005
----------------------
Frank Lazauskas


                                      II-6