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

DIVISION OF
  CORPORATION FINANCE

January 9 , 201 5

Via E -mail
David Rector
Chief Executive  Officer
Great West Resources, Inc.
1990 N. California Boulevard, 8th Floor
Walnut Creek, California 94596

Re: Great West Resources, Inc.
  Current Report  on Form 8-K
  Filed December 16 , 2014
  File No. 0-25097

Dear M r. Rector :

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 by amending your filing  and providing the requested
information .  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.

Changes to the Business, page 2

1. Please provide background information as to the business reasons and circumstances
for your change from “potash mining and exploration” to selling “mobile voice, data
and communications services targeting government, defense industry and commercial
users” where your sole officer and director, Mr. David Rector, does not have
experience in the satellite teleco mmunications industry.

Description of Current Business, page 3

2. Please revise to clarify what business activities the company is currently engaged in
and clearly distinguish those activities which are planned for the future.  It appears
that under the Glo balstar contracts you are continuing to provide mobile voice, data
and communications services to GTC’s existing customers who are serviced under

David Rector
Great West Resources, Inc.
January 9 , 201 5
Page 2

 those contracts.  Please clarify how you are able to carry on this business with one
part-time officer who has  no experience in the field, a part -time consultant, and no
employees.

3. Please clarify your business plan by providing more specific information regarding
the practical steps that you will need to take in order to make your business fully
operational  and profitable.  You state on page 2 that you intend to “carry on the
portion of GTC’s business related to the Globalstar Contracts . . . ,” as well as to
become a reseller of equipment and services.  Please explain clearly what you will
need to do in order t o be able to offer these services and equipment for sale and how
long such preparations will take.  Disclose the anticipated costs for such activities.  In
your risk factor section you refer to a need for significant additional capital and you
describe pro duct development as a long, expensive process.  We also note your
disclosure that David Rector has no experience in this industry and that you have no
other employees.

4. Disclose with greater specificity the nature of the products and services you intend to
offer.  You frequently refer to your “solutions,” without disclosing very clearly what
the specific services and products are.  For example, it appears that you intend to sell
satellite phones.  If true, briefly explain the nature of such phones and how t hey differ
from cell phones.  When you discuss markets, explain the nature of the intended
market for each product or service.  Also, when you discuss competition, provide
greater specificity.

5. Please revise to clarify what type of products you intend to s ell through Amazon’s
website.

Employees, page 4

6. Please disclose  how many hours a week, or what percentage of his business time,
David Rector plans to devote to the company’s business.

Risk Factors, page 5

7. In the introductory  paragraph, please delete the reference to the possibility of risks
that are currently unknown or appear immaterial, which is unnecessarily confusing.

We may pursue strategic transactions in the future . . . , page 6

8. Please clarify the reason why you ant icipate the possibility of future transactions that
could cause you to make significant changes to your business profile.

If we fail to protect our intellectual property rights . . . , page 7

David Rector
Great West Resources, Inc.
January 9 , 201 5
Page 3

9. Please revise to clarify the nature of the intellectual property rights and other
proprietary rights you refer to.

Being a public company is expensive and administratively  burdensome, page 8

10.  Please revise to disclose the estimated costs of being a public company.

Because we became publ ic by means of a rever se merger  . . . , page 11

11. Please revise to clarify why you refer to the current transaction as a reverse merger,
although it appears to be an acqu isition  of assets rather than a reverse merger with a
preexisting business.  We also note that the company became public in 1999 by
means of a Form 10SB -12(g) filing.

Liquidity and Capital Resources, page 14

12. Please revise to disclose the amount of capital you anticipate that you will need to
implement your business plan and continue operations.

13. Please revise  to clarify whether David Rector is currently receiving a salary, and if so
how much; if not, disclose any plans to pay him a salary in the foreseeable future.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the  filings reviewed by the staff to be certain that they have provided all
information investors require for an informed decision.  Since the company and its
management are in possession of all facts relating to a company’s disclosure, they are
responsible f or the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a
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 defense in any proceedi ng initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Inessa Kessman , Staff Accountant, at (202) 5 51-3371 or Ivette
Leon, Assistant Chief Accountant , at (202) 551 -3351 if you have questions relating to the
financial statements.  Please contact Gregory Dundas , Attorney -Advisor,  at (202) 551 -3436 ,

David Rector
Great West Resources, Inc.
January 9 , 201 5
Page 4

 Celeste M. Murphy , Legal Branch Chief, at (202) 551 -3257, or me at (202) 551 -3810  with
any other questions.

Sincerely,

        /s/ Celeste M. Murphy for

Larry Spirgel
Assistant Director