SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -7010

       DIVISION OF
CORPORATION FINANCE

March 1, 2011

Leslie Clitheroe
President  and Chief Executive Officer
Verve Ventures Inc.
33 Turnberry Drive
Wilmslow, Cheshire Sk92QW

Re: Verve Ventures Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed February 18 , 201 1
File No.  333-171214

Dear Mr. Clitheroe :

We have reviewed your registration statement and have the following comment.

Please respond to this letter by amending your registration statement and
providing the requested information. If you do not believe our comment app ly to
your facts and circumstances or do not believe an amendment is appropriate,
please tell why in your response.

After reviewing any amendment to your registration statement and the
information you provide in response to th is comment, we may have addi tional
comments.

Exhibit 23.1

1. We have reviewed your response to comment 10 in our letter dated February 9,
2011.  The consent refers to the audit report dated December 10, 2010; however,
the audit report in the Form S -1/A is actually dated December 12, 2 010.  Please
make arrangements with your auditors to have them revise the consent
accordingly.

We urge all persons who are responsible for the accuracy of the disclosure in the
filing to be certain that the filing includes the information the Securities Act of
1933 and all applicable Securities Act rules require. Since the company and its
management are in possession of all the facts relating to a company’s disclosure,
they are responsible for the accuracy and adequacy of the disclosure they have
made.

Mr. Leslie Clitheroe
Verve Ventures Inc.
March 1, 2011
Page 2
Notwithstanding our comments, in the event you requests acceleration of the
effective date of the pending registration statement  please provide a written statement
from the company ackno wledging that:

 should the Commission or the staff, acting pursuant to  delegated authority,
declare the filing effective, it does foreclose the Commission from taking any
action with respect to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, d oes not relive the company from its full
responsibility from the adequacy and accuracy of the disclosure in 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 federa l securities laws of the
United States.

Please refer to Rules 460 and 461 regarding request for acceleration.  We will
consider a written request for acceleration of the effective date of the registration
statement as confirmation of the fact that those r equesting acceleration are aware of
their respective responsibilities under the Securities Act of 1933 and the Securities
Exchange Act of 1934 as they relate to the purpose public offering of the securities
specified in the above registration statement.  Please allow adequate time for us to
review any amendment prior to the requested effective date of the registration
statement.

You may contact Jeffrey Gordon  at (202) 551 -3866 or, in h is absence, Rufus
Decker  at (202) 551 -3769 if you have questions regardin g comments on the financial
statements and related matters .  Please contact Errol Sanderson at (202) 551 -3746  or,
in his absence, Andrew Schoeffler  at (202) 551 -3748 with any other questions or
disclosure issues .

Sincerely,

Pamela A. Long
Assistant Dir ector