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 February 18, 2026

Reginald Fubara
Chief Executive Officer
HyOrc Corporation
3050 Post Oak Boulevard, Suite 510-Q60
Houston, TX 77056

 Re: HyOrc Corporation
 Amendment No. 3 to Registration Statement on Form 10
 Filed December 31, 2025
 File No. 000-51048
Dear Reginald Fubara:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response and any amendment you may file in response
to this letter,
we may have additional comments.

Amendment No. 3 to Registration Statement on Form 10-12G
Item 1. Business
Principal Business Lines
1. Green Methanol Production, page 4

1. Please revise to state clearly here and on page 14, if true, that you
are not currently
 generating revenue under the Joint Venture Agreement with Start Lda and
that Phase 1 of
 the project may not be operational until July 2026 or later.
Item 3. Properties, page 13

2. We note your response to prior comment 3 and that your relationship with
Vaigunth
 Enertek consists of fabrication and testing, engineering and R&D
support, and limited
 manufacturing services in their facilities. We also note your disclosure
that "[t]hrough
 SRE Power and technology partner Vaigunth Enertek, we operate
engineering and
 prototyping facilities in India." Please revise your disclosure to
clarify, if true, that you
 do not operate facilities in India, but instead conduct the limited
operations listed above
 through the services provided by Vaigunth Entertek. Please also further
clarify the nature
 February 18, 2026
Page 2

 of your partnership with Vaigunth Enertek, including whether the
arrangement is covered
 by an agreement. If so, please provide a description of the material
terms of the
 agreement and file the agreement as an exhibit to the registration
statement. Refer to
 Item 601(b)(10) of Regulation S-K.
Item 15. Financial Statements and Exhibits
(b) Exhibits
5.0 - Audited Financial Statements for 2023 & 2024, page 23

3. We note your response to prior comment 7. Please address the following:
 Your disclosure of the purchase price allocation on page 18 of the
exhibit indicates
 that substantially all of the fair value of the gross assets acquired
is concentrated
 in customer relationship, a single identifiable asset, or group of
similar identifiable
 assets. Please tell us your consideration of the screen test provided
in paragraphs
 ASC 805-10-55-5A through 55-5C in determining that ASPZ (now HyOrc)
could be
 deemed a business.
 You state that ASPZ pursued mineral-related initiatives and the
performance of due
 diligence and evaluation activities constituted substantive processes
essential to
 developing a revenue-generating operation. Please describe your
business inputs and
 substantive process in greater detail. Tell us whether your process
includes
 employees that form an organized workforce with the necessary skills,
knowledge or
 experience to perform the process. Refer to ASC 805-10-55-5D.
6.0 - Unaudited Interim Financial Statements for September 2025, page 23

4. We note your response to prior comment 1. However, we were not able to
locate your
 results of operations and cash flow discussions for the interim period
ended September
 30, 2025 in the MD&A section. Please revise your filing to provide the
information
 required in Item 303 of Regulation S-K.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

 Please contact Suying Li at 202-551-3335 or Angela Lumley at
202-551-3398 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Reginald L. Sewell
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