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SEC Company Response from Graphene & Solar Technologies Ltd (GSTX) (CIK 0001497649) (GSTX) — Sep 15, 2011

Graphene & Solar Technologies Ltd (GSTX) (CIK 0001497649)
Date: Sept. 15, 2011 · CIK: 0001497649 · Accession: 0001004878-11-000300

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File numbers found in text: 333-174194

Referenced dates: August 19, 2011

Date
September 14, 2011
Author
HART & TRINEN, L.L.P.
Form
CORRESP
Company
Graphene & Solar Technologies Ltd (GSTX) (CIK 0001497649)

Letter

Re: Vanguard Energy Corporation Registration Statement on Form S-1 File No. 333-174194

HART & TRINEN, LLP ATTORNEYS AT LAW 1624 Washington Street Denver, CO 80203 William T. Hart, P.C. ________ Email: harttrinen@aol.com Donald T. Trinen Facsimile: (303) 839-5414 (303) 839-0061 --

Will Hart

September 14, 2011

Parker Morrill Securities and Exchange Commission 100 F Street, NE Washington, DC 20549

This office represents Vanguard Energy Corporation (the "Company"). Amendment No. 3 to the Company's registration statement on Form S-1 has been filed with the Commission. This letter provides the Company's responses to the comments received from the staff by letter dated August 19, 2011. The paragraph numbers in this letter correspond with the numbered paragraphs in the staff's comment letter. The number under the "page number" column indicates the page number in the Registration Statement where the response to the comment can be found.

Page Number -----------

1. Comment complied with. F-1

2. Comment complied with. 4

3. Comment complied with. 7

4. Comment complied with. 25, F-16

5. The form of lock-up agreement is Exhibit B to the Underwriting Agreement, which was filed with the original Registration Statement (Exhibit 1.1). The lock-up agreements have not yet been signed (nor for that matter, has the underwriting agreement been signed). The signed lock-up agreements will typically be delivered to the underwriter when the underwriting agreement is signed. --

6. Comment complied with. 47

7. Comment complied with. Exhibit 99

<PAGE>

If you should have any questions concerning the foregoing, please do not hesitate to contact the undersigned.

Very Truly Yours,
HART & TRINEN, L.L.P.

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                               HART & TRINEN, LLP
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________           Email:  harttrinen@aol.com
Donald T. Trinen                                      Facsimile:  (303) 839-5414
                               (303) 839-0061
--

Will Hart

                               September 14, 2011

Parker Morrill
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   Vanguard Energy Corporation
            Registration Statement on Form S-1
            File No. 333-174194

     This  office  represents   Vanguard  Energy  Corporation  (the  "Company").
Amendment  No. 3 to the  Company's  registration  statement on Form S-1 has been
filed with the Commission.  This letter provides the Company's  responses to the
comments  received from the staff by letter dated August 19, 2011. The paragraph
numbers in this letter  correspond  with the numbered  paragraphs in the staff's
comment  letter.  The number under the "page number"  column  indicates the page
number in the  Registration  Statement  where the response to the comment can be
found.

                                                                     Page Number
                                                                     -----------

1.     Comment complied with.                                               F-1

2.     Comment complied with.                                                 4

3.     Comment complied with.                                                 7

4.     Comment complied with.                                          25, F-16

5.     The form of lock-up agreement is Exhibit B to the
       Underwriting Agreement, which was filed with the
       original Registration Statement (Exhibit 1.1). The
       lock-up agreements have not yet been signed (nor
       for that matter, has the underwriting agreement
       been signed). The signed lock-up agreements will
       typically be delivered to the underwriter when the
       underwriting agreement is signed.                                     --

6.     Comment complied with.                                                47

7.     Comment complied with.                                        Exhibit 99

<PAGE>

     If you should have any questions  concerning the  foregoing,  please do not
hesitate to contact the undersigned.

                                           Very Truly Yours,

                                           HART & TRINEN, L.L.P.

                                           By /s/ William T. Hart
                                              -------------------
                                              William T. Hart

<PAGE>
</TEXT>
</DOCUMENT>