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    stevenscorresp121609.htm

    STEVENS
RESOURCES, INC.

    Security
and Exchange Commission

    Division
of Corporate Finance

    100 F
Street, N.E.

    Washington
D.C. 20549-4628

                                                                                                                                   December
16, 2009

    Re:                       Stevens Resources,
Inc.

    Registration Statement Form
S-1

    File
Number 333-163019

    Filed:
November 10, 2009

    Attention:              Mr.
Parker Morrill

    Phone (202) 551-3696

    Fax     (703)
813-6982

    Stevens
Resources, Inc. (the “Company”) has received your comments dated December 4,
2009 regarding the Form S-1 filed on November 10, 2009. The following document
as prepared by the Company describes the general action(s) taken regarding each
comment made by the Commission. The following numbers herein are referenced to
the comment number provided on the document sent by the Commission.

    Financial Statements, page
24

    Report of Independent
Registered Public Accounting Firm, page F-1

    1.           The
revised report provided by the accountant reflecting the appropriate period of
financial results is included in the amended S-1.

    Statement of Operations,
page F-3 and Statement of Cash Flows, page F-5

    2.           The
financial statements (statement of operations and statement of cash flows) have
been modified to include the required “cumulative from inception” columnar
information.

    Notes to Financial
Statements, page F-6

    General

    3.           Notes
to the Financial Statements within the S-1 have been amended to reflect the
revised references to accounting standards.

    Note 7-Prepaid Expenses,
page F-12

    4.           Jameson
Capital, LLC was issued 100,000 shares with a value of $0.02 per share ($2,000)
on September 30, 2009 for the service of providing consultation in completion of
the registration statement filed on Form S-1 including any amendments as
required thereto.  At September 30, 2009 there was no services
performed.  As of the date of this document the consultant has
provided services relating to the S-1 filed on November 10, 2009 as well as has
provided services relating to the amendment detailed herein.

          1818
West Francis, Ste. 196

          Spokane,
Washington 99205

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          STEVENS
RESOURCES, INC.

    Management’s Discussion and
Analysis, page 25

    Plan of Operations, page
26

    5.           Caption
headings have been added to the Tables describing estimated costs for both Phase
I and Phase II, indicating the projected level of shares sold to anticipated
costs or expenditures.

    6.           Statement
of Operations section has been modified to better disclose the effects of not
raising the full amount of the offering.

    Contractual Obligations,
page 32

    7.           Table
has been added to this section disclosing the Option Agreement the Company
currently has in place with American Mining Company (as was filed as exhibit
10.1 to the registration statement).

    Purchase of Equity
Securities by the Small Business Issuer and Affiliates, page
34

    8.           This
section has been modified to reflect the share purchased by Mr. Miller on
September 28, 2009.

    Certain Relationships and
Related Transactions, page 34

    9.           The
phrase indicating there are no promoters has been removed from the registration
statement.

    10.           The
100,000 shares issued to Jameson Capital, LLC has been recorded as issued for a
value of $2,000 for services rendered throughout the document for services
rendered in completion of the registration statement and within the financial
statements as well.  No services were rendered by the consultant as of
September 30, 2009.  As of the date of the filing of the 1st
amendment to the registration statement services have been rendered by the
consultant.

    Undertakings, page
II-3

    11.           Undertakings
have been modified to exact form under Regulation S-K Item 512.

    Exhibits

    12.           It
is the understanding that the certifications required by Regulation S-K, Item
601(31) for Securities Act Form S-1 is not applicable.  Please advise
if we are misunderstanding the comment and provide further details so we may
address the issue if needed.

    Sincerely,

    /s/Justin
Miller________

    Justin
Miller

    Chief
Executive Officer

    Stevens
Resources, Inc.

          1818
West Francis, Ste. 196

          Spokane,
Washington 99205

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