SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

         February 27, 2012
 Via U.S. Mail

Mr. George Glasier President and Chief Executive Officer American Strategic Minerals Corporation 31161 Highway 90
Nucla, CO 81424

 Re: American Strategic Minerals Corporation
  Current Report on Form 8-K   Filed January 31, 2012   Current Report on Form 8-K   Filed February 3, 2012   File No. 333-171214

Dear Mr. Glasier:
We have reviewed your filings and have the comments below.  In some of our comments,
we may ask you to provide us information so that we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, please tell us why in your response

After reviewing the information you provide in response to these comments, we may
have additional comments.
8-K filed January 31, 2012

General
 1. Update your EDGAR company pr ofile to reflect th e current address of your principal
executive offices.
 2. The EDGAR system indicates that your primar y standard industrial classification or SIC
code number is 4950.  Please contact EDGAR oper ations to request a SIC code number that
reflects your current business.

Mr. George Glasier
American Strategic Minerals Corporation February 27, 2012 Page 2

Completion of Acquisition or Di sposition of Assets, page 3

 3. We note the statement that “following the Split-Off, 7,500,000 shares  will constitute our
“public float” and will be our only shares that  have been registered for resale under the
Securities Act of 1933.”  We also note the firs t paragraph on page 5.  Please advise us on
when this registered resale offering occu rred.  We may have additional comments.
 4. Please describe the services to be provided  by GRQ Consultants, identify the parties and
purpose of the additional consulta nt warrant agreement, and f ile the executed agreement as
an exhibit.
 Description of Current Business, page 5

 5. Please file the mining lease agreements for the Cutler King, the Dunn, the Centennial-Sun
Cup, the Bull Canyon, the Martin Mesa, the Aval anche/Ajax, and the Home Mesa properties
as exhibits to the Form 8-K.  See
 Item 601(b)(10) of Regulation S-K.
 6. Please disclose that you have not  begun any operations at your ta rget properties, and describe
what is meant by “historical exploration” for each of the properties.  For instance, clarify
whether the property covered by the claims was ever subject to extractive operations and
generated any revenue.
 Properties, page 15

 7. Please file the anticipated leas e agreement, or form thereof, for your principal place of
business as an exhibit to this Form 8-K and f ile an executed version with an amended 8-K or
other Exchange Act filing.  See
 Item 601(b)(10) of Regulation S-K.
 Forward-Looking Statements, page 20

 8. We note the statement “We…cannot assure investor s of the accuracy or completeness of the
data included in this Curren t Report.”  Since you may not disclaim responsibility for
information that you have chosen to in clude in the Form 8-K, please revise.
 Security Ownership of Certain Beneficial  Owners and Management, page 26; Certain
Relationships and Related Transactions, page 31; Security Ownership of Certain Persons, page
32
 9. The disclosure in footnote (14)  on page 26 is unclear.  Clarif y whether Messrs. Joshua Bleak,

Mr. George Glasier
American Strategic Minerals Corporation February 27, 2012 Page 3
 Barry Honig, and David Rector share voting and investment power over the shares of
common stock of American Strategic Minerals Corporation that are beneficially owned by
Sagebrush.  Alternatively, if only one natura l person has voting and investment power over
the shares of common stock of American Strategi c Minerals Corporation that are beneficially
owned by Sagebrush, identify that natural person.  As appropriate, revise also the disclosures
on pages 31 and 32.
 Security Ownership of Certain Persons, page 32

 10. In light of the percentage of shares owned by Sagebrush, please explain the statement in the
third paragraph of this section th at “None of the foregoing persons is an officer or director of
the Company, and the Company does not consider any of such persons, i ndividually or in the
aggregate, to be in a position to exercise cont rol over the business or affairs of the Company
as a result of the ownership of our securities or otherwise.”
 Exhibits 10.1, 10.3, 10.7, and 10.9

 11. We note that you did not file the attachments to the exhibi ts filed as exhibits 10.1, 10.3, 10.7,
and 10.9.  Unlike Item 601(b)(2) of Regulation S-K,  there is no provision in Item 601(b)(10)
of Regulation S-K for excluding attachments.  Please refile the exhibits with their
attachments.

8-K filed February 3, 2012

 Exhibit 10.1

 12. We note that you did not file the attachments to the exhibi t filed as exhi bit 10.1 although
it appears that exhibits B a nd D were filed as exhibits 10.2 and 10.3.  Unlike Item 601(b)(2)
of Regulation S-K, there is no provision in Item 601(b)(10) of Regulation S-K for excluding
attachments.  Please refile exhi bit 10.1 with its attachments.
 Closing

  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in
the filings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures that they have made.
In responding to our comments, please provi de a written statement from the company
acknowledging that:

Mr. George Glasier
American Strategic Minerals Corporation February 27, 2012 Page 4

 The company is responsible for the adequacy  and accuracy of the disclosure in the
filings.

 Staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filings.

 The company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

You may direct questions on comments and disc losure issues to Edward M. Kelly at 202-
551-3728 or Craig E. Slivka at (202) 551-3729 if  you have any questions on the comments.

Very truly yours,
        / s /  C r a i g  E .  S l i v k a ,  f o r
Pamela A. Long Assistant Director
 cc: Via Facsimile

 Harvey J. Kesner, Esq.  Sichenzia Ross Friedman Ference LLP  61 Broadway, 32nd Floor
 New York, NY 10006