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Via Facsimile and U.S. Mail Mail Stop 4720         March 11, 2010  Martin Schmieg Chief Executive Officer Nuvilex, Inc. 1971 Old Cuthbert Road Cherry Hill, NJ 08034

Re: Nuvilex, Inc.
Item 4.01 Form 8-K   Filed March 9, 2010
 File No. 333-68008
Dear Mr. Schmieg:
 We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comments are inapplicable
or a revision is unnecessary.  Please be as detailed as necessary in your explanation.
After reviewing this information, we may raise additional comments.   Please understand that the purpose of our re view 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 any other aspect of our
review.  Feel free to call us at the telephone number listed at  the end of this letter.
 Item 4.01(a)

 1. Please revise the second paragraph of your  filing to state whether during the two
most recent fiscal years and any subs equent interim period preceding such
dismissal there were any disagreements with the former accountant.  You should
specify the subsequent interim period as  the interim period through the date of
dismissal which was March 8, 2010.  Your  current disclosure only goes through
October 31, 2009.

Martin Schmieg
Nuvilex, Inc. March 11, 2010 Page 2  2. Please revise the third paragraph of your filing to specify the subsequent interim
period as the interim period through the da te of engagement which was March 8,
2010. Your current disclosure only goes through March 1, 2010.
 3. Item 304(a)(1)(ii) of Regulation S- K requires a statement whether the
accountant's report on the financ ial statements for either of the past two years
contained an adverse opinion or a disc laimer of opinion or was qualified or
modified as to uncertainty, audit scope or accounting principles; and a description
of the nature of each such adverse opin ion, disclaimer of opinion, modification or
qualification.  This would include disclosu re of uncertainty regarding the ability
to continue as a going con cern in the accountant’s report .  It appears Gruber &
Company, LLC disclosed an uncertainty re garding your ability to continue as a
going concern in your Form 10-K file d August 13, 2009. Please revise your
disclosure to provide a description of the nature of their conclusion.

4. To the extent that you make changes to the Form 8-K to comply with our
comments, please obtain and file an upda ted Exhibit 16 letter from the former
accountant stating whether the accountant ag rees with the statements made in
your revised Form 8-K.
   As appropriate, please amend your fili ng and respond to these comments within
five business days or tell us when you will re spond.  You may wish to provide us with
marked copies of the amendment to expedite our review.  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
understand that we may have additional comm ents 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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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

Martin Schmieg
Nuvilex, Inc. March 11, 2010 Page 3
States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.     If you have any questions, please call me at (202) 551-3649.
         S i n c e r e l y ,            Vanessa Robertson        S t a f f  A c c o u n t a n t