Exhibit 31.02

     CERTIFICATION OF PRINCIPAL FINANCIAL OFFICER PURSUANT TO RULE
     13A-14(A) OF THE SECURITIES EXCHANGE ACT AND SECTION 302 OF THE
                       SARBANES-OXLEY ACT OF 2002

I, Michael Lee, Chief Accounting Officer of Focus Affiliates, Inc.,
certify that:

1. I have reviewed this Quarterly Report on Form 10-Q of Focus
   Affiliates, Inc.

2. Based on my knowledge, this report does not contain any untrue statement
   of a material fact or omit to state a material fact necessary to make the
   statements made, in light of the circumstances under which such statements
   were made, not misleading with respect to the period covered by this
   report;

3. Based on my knowledge, the financial statements, and other financial
   information included in this report, fairly present in all material
   respects the financial condition, results of operations and cash flows of
   the of the registrant as of, and for, the periods presented in this
   report;

4. The registrant's other certifying officer and I are responsible for
   establishing and maintaining disclosure controls and procedures (as
   defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal
   control over financial reporting ( as defined in Exchange Act Rules 13a-
   15(f) and 15d-15(f)) for the registrant and have :

a. Designed such disclosure controls and procedures, or caused such
   disclosure controls and procedures to be designed under our supervision,
   to ensure that material information relating to the registrant, including
   its consolidated subsidiaries, is made known to us by others within those
   entities, particularly during the period in which this report is being
   prepared;

b. Designed such internal control over financial reporting, or caused such
   internal control over financial reporting to be designed under our
   supervision, to provide reasonable assurance regarding the reliability of
   financial reporting and the preparation of financial statements for
   external purpose in accordance with general accepted accounting
   principles;

c. Evaluated the effectiveness of the registrant's disclosure controls and
   procedures and presented in this report our conclusions about the
   effectiveness of the disclosure controls and procedures, as of the end of
   the period covered by this report based on such evaluation; and

d. Disclosed in this report any change in the registrant's internal control
   over financial reporting that occurred during the registrant's most recent
   fiscal quarter ( the registrant's fourth fiscal quarter in the case of an
   annual report ) that has materially affected, or is reasonably likely to
   materially affect, the registrant's internal control over financial
   reporting.

5. The registrant's other certifying officer and I have disclosed, based on
   our most recent evaluation of internal control over financial reporting,
   to the registrant's auditors and the audit committee of the registrant's
   board of directors ( or persons performing the equivalent functions ):

a. All significant deficiencies and material weaknesses in the design or
   operation of internal control over financial reporting which are
   reasonably likely to adversely affect the registrant's ability to record,
   process, summarize and report financial information; and

b. Any fraud, whether or not material, that involves management or other
   employees who have a significant role in the registrant's internal control
   over financial reporting.



Dated : October 17, 2008        Signature :  /s/ Michael Lee
                                             -------------------------------
                                             Michael Lee
                                             Chief Accounting Officer


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