SecProbe.io

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December 2, 2005

Mail Stop 3561

via U.S. mail and facsimile

David C. Merrell, President
Souvall-Page and Company, Inc.
9005 Cobble Canyon Lane
Sandy, Utah

Re: Souvall-Page and Company, Inc.
       Registration Statement on Form 10-SB, Amendment 1
       Filed September 26, 2005
       File No. 0-51464

Dear Mr. Merrell:

      We have the following comments on your filing. 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 may ask you to provide us with supplemental
information
so we may
better understand your disclosure.  After reviewing this
information,
we may or may not 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.

General
1. Please revise the entire filing to use the same title for each
category of stock that you have used in your Articles of
Incorporation, as amended.  For example, if correct, use "common
stock" to refer to the 75,000,000 shares you initially issued and
"Class A common stock" to refer to the 50,000,000 shares of stock
now
outstanding.
2. We have reviewed your revisions in response to comment number
two
of our letter dated September 20, 2005.  Please discuss whether or
not you have redeemed or retired the 75,000,000 shares of common
stock that you authorized in your initial Articles.  We note that
you
have stated in the prospectus in the fourth paragraph of Part I,
Item
1. "Description of Business - Business Development - Organization"
on
page 2 the following:

"Effective February 2, 1988, we changed our name to Souvall-Page
and
Company, Inc. and we decreased our authorized capital of
75,000,000
shares of $0.001 par value common stock to 50,000,000 shares of
Class
A common stock without par value, ("Common Stock")."

We also note that your "Articles of Amendment to the Articles of
Incorporation to Black Gold Resources," (your former name), which
you
have filed as Exhibit 3.2, reference only the Class A common
stock.
3. Please revise any disclosure throughout the registration
statement
that states that you may be deemed to be a blank check company.
Instead, state that you are, or you are deemed, a blank check
company.  See, for example, risk factors numbers two and four.
4. Please file on EDGAR a marked version of all future amendments.

General Business History, page 3
5. Please revise the fifth paragraph of this section, and the rest
of
the registration statement disclosure as appropriate, to discuss
the
effects of the Division`s letter to the NASD Regulation, Inc.
disclosed under "Restrictions on sales of certain restricted
securities."
6. Please resolve the discrepancy between the disclosure in the
second paragraph of this section about pursuing the creation of a
"national and international marketing network for the commercial-
investment real estate community" and your disclosure elsewhere
that
you are a blank check company.

Business, page 3
7. Clarify the following:  "Our Company is not currently engaged
in
any substantive business activity, and we have no plans to engage
in
any such activity in the foreseeable future."  For example, do you
mean that you will not engage in a substantive business activity
until you acquire, or merge with, another company, or do you mean
that you do not intend to acquire or merge with another company in
the foreseeable future?

Risk Factors, page 5
8. Please add the following as a risk factor and, also, include it
in
the section, "Description of Securities," on page 18.  It is from
Article VI, number four of your "Articles of Amendment to the
Articles of Incorporation to Black Gold Resources," (your former
name), which you have filed as Exhibit 3.2.

"The company may at any time and from time to time at the option
of
the board of directors, redeem the whole or any part of the
outstanding Class A Common Stock upon any redemption date fixed by
the board of directors."

Plan of Operation, page 13
9. Please explain what you mean by "through funding" in the first
paragraph.
10. Identify the individual manager who has agreed to loan the
company money for "investigating a potential business venture."
Disclose all principal terms of the agreement, including whether
the
manager has agreed to loan you the full $25,000 if you need it.
State whether the agreement is written or oral and, if written,
file
as an exhibit.

Liquidity, page 14
11. We have reviewed your response to comment number 12 of our
prior
letter dated September 20, 2005.  Please disclose the principal
terms
of any oral agreements with officers and directors regarding
expenses
of $3,699 paid in 1998.

Restrictions of Sales of Certain Restricted Securities, page 18
12. In the last paragraph, please list all categories of persons
subject to the letter issued to NASD Regulation, Inc., which you
describe in this section.  For example, it appears you have
omitted
promoters and transferees of promoters and affiliates.

Indemnification, page 21
13. Please include in the indemnification section of the
prospectus
the information in Article IX, numbers four and eleven of your
Articles of Amendment to the Articles of Incorporation to Black
Gold
Resources, (your former name), which you have filed as Exhibit
3.2.
Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  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 supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      You may contact Blaise Rhodes at (202) 551-3774 if you have
questions
regarding the financial statements and related matters.  Please
contact Susann Reilly at (202) 551-3236 with other questions.

      Sincerely,

       John D. Reynolds
       Assistant Director
       Office of Emerging Growth Companies

      cc:   Leonard Burningham
      By facsimile to 801-355-7126

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David C. Merrell, President
Souvall-Page and Company, Inc.
December 2, 2005
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