SecProbe.io

November 26,  2012

Via E -mail
J. Michael King
Broadleaf Capital Partners
3887 Pacific Street
Las Vegas, NV 89121

Re: Broadleaf Capital Partners, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2011
Filed April 3, 2012

Form 10 -Q for the Quarter Ended September 30, 2012
Filed November 6, 2012

File No. 814-00175

Dear Mr. King :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2011
Cover Page
 We note that on the cover page of the Form 10 -K, you indicate that the registrant is not a 1.
shell comp any as defined under Rule 12b -2 of the Exchange Act.  We also note that the
registrant appears to have had nominal operations and assets consisting of cash and
nominal assets.  Please advise us how the registrant is not a shell company or revise this
discl osure in future Exchange Act periodic reports.

J. Michael King
Broadleaf Capital  Partners
November 26, 2012
Page 2

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 9
 We believe your MD&A section could benefit from an expanded “Overview” section that 2.
offers investors an introductory understanding of the registrant and the matters with
which management is concerned primarily in evaluating the company’s financial
condition and operating results.  A good introduction, accordingly, might include a
discussion of the following:   the economic or industry -wide factors relevant to the
company; a discussion of how the company earns or expects to earn revenues and
income; the identity of the company’s primary business lines, location(s) of operations
and principal services; and insig ht into material opportunities, challenges, risks, and
material trends and uncertainties.  For a more detailed discussion of what is expected in
both this subheading and the MD&A section in general, please refer to SEC Release No.
33-8350  (Dec. 19, 2003 ).  See also  Item 303 of Regulation S -K.
 We note your intention to operate your business through your parent company.  Please 3.
revise your Business section in future filings to address your corporate structure and
discuss the business of each entity.
Item 9( A)(T). Controls and Procedures, page 34
 We note that management determined that you had ineffective internal controls for the 4.
period presented.  Please revise to discuss the remediation plans, if any, to cure the noted
deficiencies.
Item 10. Directors, Exe cutive Officers and Corporate Governance, page 35
 With respect to your directors, please revise to explicitly discuss the specific experience, 5.
qualifications, attributes or skills that led to the conclusion that the person should serve as
a director , in light of your  business and structure .  Please refer to Item 401(e) of
Regulation S -K for guidance
Signatures, page 42
 In future filings, please include the signatures of your principal executive officer and 6.
principal accounting officer or controller.  Plea se refer to General Instruction D(2)(a) of
Form 10 -K for guidance.
Exhibits
 Please file a list of subsidiaries exhibit or advise.  Refer to Item 601(b)(21) of Regulation 7.
S-K for guidance.

J. Michael King
Broadleaf Capital  Partners
November 26, 2012
Page 3

 Exhibit 31.1
 Please tell us if Mr. King is your principal executiv e officer as well as your principal  8.
financial officer.  We may have further comment.
 We note the introductory paragraph of your certification in which you indicate that the 9.
certification covers both the fiscal years ended December 31, 2011 and December 31,
2010.  Please note that a certification should only identify the period to which it relates.
Please revise this paragraph accordingly in your future Exchange Act periodic reports.
Form 10 -Q for the Quarter Ended September 30, 2012
Item 2. Description of Business , page 22
 We note your disclosure in this section that the registrant’s investment focus is centered 10.
on real estate and finance.  We also note your disclosure in the MD&A section that the
company’s only revenues are from sales from its majority owned -subsidiary Pipeline
Nutrition, Inc.  In future Exchange Act periodic reports, please describe in this section the
business of your subsidiary Pipeline Nutrition, Inc.  Please be sure to include any material
arrangement or agreements regarding Pipelin e Nutrition, Inc.
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
22
Results of Operations 2012 -2011, page 24
 We note your disclosure regarding  the company beginning  to record sales from its 11.
subsidiary Pipeli ne Nutrition, Inc.  In future Exchange Act periodic reports, please
describe these sales in greater detail.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the  disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to  disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the f ederal securities laws of the United States.

J. Michael King
Broadleaf Capital  Partners
November 26, 2012
Page 4

Please contact Erin E. Martin, Attorney -Advisor, at (202) 551 -3391 or me at (202) 551 -
3233  with any other questions.

Sincerely,

 /s/ Tom Kluck

Tom Kluck
Branch Chief