SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628

     DIVISION OF
CORPORATION FINANCE

November 10, 2009

Ms. Lynn Briggs Chief Executive Officer Saguaro Resources, Inc. 71 The Mead Darlington, Durham DL1 1EU United Kingdom
Re: Saguaro Resources, Inc.  Amendment No. 1 to Registra tion Statement on Form S-1
 Filed October 30, 2009  File No. 333-162168
 Dear Ms. Briggs:

We have reviewed your response letter and your amended filing and have the following
comments.  Where indicated, we think you should revise your registration st atement in response to
these comments.  If you disagree, we will consid er your explanation as to why our comments are
inapplicable or a revision is unnecessary.  Please be as detailed as necess ary in your explanation.
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 ove rall disclosure in your filing.
We look forward to working with you in these respects.  We welcome any questions you might
have about our comments or 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 monitor the age of your financial stat ements.  See Item 8-08 of Regulation S-X.

Risk Factors, page 4

2. We note your response to our prior comment 14.  Please provide a risk factor addressing the
fact that since 1999 James McLeod has been an officer, director, or geologist for over twenty companies, most of which have not m oved forward with exploration activities, and
at least five of which have changed businesses and completely abandoned exploration activities.

Ms. Lynn Briggs
Saguaro Resources, Inc.
November 10, 2009 Page 2   Use of Proceeds, page 10

 3. We note your response to prior comment 10, and we  reissue that comment in relevant part.
In each instance where you discuss Ms. Briggs’s  verbal agreement to loan funds, include
each item of expense for which she has agreed to loan the company money.  In this regard, we note your disclosure in the final paragraph of the “Use of Proceeds” section on page 10,
and your disclosure in the second paragraph of the “Liquidity a nd Capital Resources”
section on page 29.

Exhibits

4. We note your disclosure at page 13 that the source of information contained in your discussion regarding the Sky Property is the report prepared by James McLeod.  Please file as an exhibit to your filing a consent from  Mr. McLeod that expressly states that he
consents to your references to him in the regi stration statement.  This consent should concur
with the summary of the information in the repo rt disclosed, and agree to being named as an
expert in your registration statement.

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 expe dite our review.  With
your amendment, please furnish a cover letter th at keys your responses to our comments and
provides any requested information.  Detailed cove r letters greatly facilitate our review.  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 al l information required under  the Securities Act of
1933 and that they have provided all information investors require for an informed investment
decision.  Since the company and its management  are in possession of a ll facts relating to a
company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they
have made.       In addition, please be advised that the Division of Enforcemen t has access to all information
you provide to the staff of the Di vision of Corporation Finance in connection with our review of
your filing or in response to our comments on your filing.
We will consider a written request for acceleration of the effective date of the registration
statement as confirmation of the f act that those requesting accelera tion are aware of their respective
responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they
relate to the proposed public offeri ng of the securities sp ecified in the above registration statement.

Ms. Lynn Briggs
Saguaro Resources, Inc. November 10, 2009 Page 3   We will act on the request and, pursuant to delegate d authority, grant acceleration of the effective
date.
We direct your attention to Rules 460 and 461 regarding requesting acceleration of a
registration statement.  Please a llow adequate time after the fili ng of any amendment for further
review before submitting a request for acceleration.  Please provide this request at least two business days in advance of the requested effective date.    Please contact John Lucas at (202) 551-5798 or, in his absence, Laura Nicholson at (202)
551-3584 with any questions.
Sincerely,

H. Roger Schwall Assistant Director

   cc:   Via Facsimile

  Abby L. Ertz, Esq.  (619) 564-8753