SecProbe.io

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      August 16, 2005

Mail Stop 4561

Mr. Richard J. Verdiramo
President
RECOV Energy Corp.
3163 Kennedy Boulevard
Jersey City, NJ 07306

Re:	RECOV Energy Corp.
	Form 10-KSB for the year ended March 31, 2005
	Filed July 15, 2005
	File No. 0-30230

Dear Mr. Verdiramo:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we ask you to provide us with information
so
we may better understand your disclosure.  After reviewing this
information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB for the year ended March 31, 2005

Consolidated Financial Statements

Consolidated Income Statement, page 12

1. We note that in September 2002, you ceased operations of your
wholly owned subsidiaries, AutoSmart USA, Inc. and AutoSmart
Leasing,
Inc.  Please advise us of the facts and circumstances resulting in
the gain you recognized from the reduction of debt of discontinued
subsidiary.  Please identify the creditor in your response.  Also,
describe the terms under which you were released from this
obligation
and explain how you considered paragraph 16 of SFAS 140 in
recognizing a gain on the transaction.

Consolidated Statement of Cash Flows, page 14

2. Please revise to present proceeds from the issuance of common
stock as a financing activity pursuant to paragraph 19 of SFAS 95.

Note 3 - Details of Financial Statement Components, page 18

3. Please explain how you have applied the guidance in EITF 00-2
in
accounting for website costs.  Additionally, tell us the period
over
which you amortize these costs and how you test these assets for
impairment.  If you have recently tested them for impairment,
please
tell us the results of that test.

Note 7 - Related Party Transactions, page 19

4. We note that your notes payable are convertible into common
stock
at the rate of $0.185 per common share.  Please advise us how you
considered EITF 98-5 in accounting for the conversion feature.
Based
upon your disclosure, it appears that you have not allocated any
proceeds to this item.

Consolidated Statement of Operations, page 22

5. We note that effective on the close of business on March 28,
2005,
you implemented a reverse stock split of your common stock on the
basis of twenty shares pre-consolidation for one share post-
consolidation.  Please revise your statement of operations to
reflect
the change in capital structure by retroactively restating basic
and
diluted loss per share for all periods presented.  Refer to
paragraph
54 of SFAS 128.

Item 8A - Controls and Procedures, page 34

6. Pursuant to Item 307 of Regulation S-B, please revise to
disclose
the conclusions of your president and principal accounting officer
regarding the effectiveness of your disclosure controls and
procedures as of the end of the period covered by the report.

Exhibit 31 - Certifications

7. Please provide a separate certification for your principal
financial officer pursuant to Item 601 of Regulation S-B.

*    *    *    *
      As appropriate, please amend your Form 10-KSB and respond to
these comments within 10 business days or tell us when you will
provide us with a response.  Please furnish a cover letter with
your
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please file your cover letter on EDGAR.  Please
understand
that we may have additional comments after reviewing your
amendment
and responses to our comments.

	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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 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 a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Rachel Zablow, Staff Accountant at (202)
551-
3428 or the undersigned at (202) 551-3403 if you have questions.

						Sincerely,

Steven Jacobs
Accounting Branch Chief
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Mr. Richard J. Verdiramo
RECOV Energy Corp.
August 16, 2005
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