SecProbe.io

June 16, 2011
 Via E-Mail

Mr. George Konrad Chief Executive Officer PowerVerde, Inc. 23429 N. 35
th Drive
Glendale, AZ   85310
Re: PowerVerde, Inc.
 Form 10-K for the year ended December 31, 2010
Filed April 7, 2011 Form 10-Q for the quarterly  period ended March 31, 2011
Filed May 23, 2011 File No. 0-27866

Dear Mr. Konrad:
 We have reviewed your filing and have the following comments.  We have limited our
review to only your financial statements and re lated disclosures and do not intend to expand our
review to other portions of your documents.  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 te n business days 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 circum stances, please tell us w hy in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.               Form 10-K for the year ended December 31, 2010

 Consolidated Statements of Operations, page F-5

 1. We note your disclosure regarding other income as of December 31, 2010 of $26,371.
Please describe for us, and revise future filings here and in MD&A to disclose what this amount represents and how it satisfies the c ondition for classification as other income.
Provide us with a sample of your proposed disc losure.  This comment also applies to your
Form 10-Q for the quarter ended March 31, 2011.

Mr. George Konrad PowerVerde, Inc. June 16, 2011 Page 2

Form 10-Q for the Period Ended March 31, 2011

 Note 7 – Stock Options, page 8

 2. We note from your disclosures that you util ize the Black-Scholes stock option pricing
model to determine the fair value of your stoc k options.  Please revise future filings to
explain how you determined the assumptions ut ilized in these mode ls including volatility,
risk-free interest rate , expected life, etc.  Refer to  the guidance in paragraph 750-10-50-
2(f)(2) of the FASB Accoun ting Standards Codification.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact David Burt on, Staff Accountant, at ( 202) 551-3626 or Lynn Dicker,
Reviewing Accountant, at (202)  551-3616 if you have questions regarding these comments. In
this regard, do not hesitate to contact me at (202) 551-3643.

        S i n c e r e l y ,           /s/ Lynn Dicker for           Kevin L. Vaughn              Accounting Branch Chief