SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

         November 27, 2012

Via E-mail
Mr. Mark Groussman
Chief Executive Officer
American Strategic Minerals Corporation
c/o National Corporate Research Ltd.
202 South Minnesota Street
Carson City, NV 89703

 Re: American Strategic Minerals Corporation
  Revised Preliminary Information Statement on Schedule 14C
  Filed November 8 , 201 2
  File No. 0-54652

Dear Mr. Groussman :

We have reviewed yo ur filing and have the following comments.  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 10 business days by amending your filing, by
providing the requested information, or by adv ising us when you will p rovide the requested
response.  If you do not believe that our comments apply to your facts and circumstances or do
not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your  filing and the information that you provide in
response to these comments, we may have additional comments.

General

1. You indicate in response to comment 1 in our November 5, 2012 letter that the solicitation of
written consents in not required because th e number of persons solicited was less than 10.
We wish to advise you that:

 The 10 person exception to solicitation under Rule 14a -2(b)(2) of Regulation 14A is
unavailable for an issuer’s solicitation.

 Action by an affiliate is usually on the issuer’s b ehalf.

Mr. Mark Groussman
American Strategic Minerals Corporation
November 27, 2012
Page 2

Please file a preliminary proxy statement on Schedule 14A.  See Rule 14a -2 of Regulation
14A.

2. Your response to comment 3 in our November 5, 2012 letter states that “The Company is
evaluating various alternative plans to the real estate business.”  As requested previously,
disclose what the company’s long term strategy and new business direction are in light of the
Form 8 -K filed on November 20, 2012.  Further, disclose what comprise the company’s
assets for its long term strategy and new business d irection.

3. Your response to comment 4 in our November 5, 2012 letter states that “The Company
presently has no plan to issue any shares of its common stock but reserves the right to
develop and act upon any such plans should it determine to do so.”  We not e that you have
filed a current report on Form 8 -K on November 20, 2012 related to a share exchange
agreement with Sampo IP LLC, a company engaged in the business of patent acquisition,
development, and monetization.  It also appears that this 8 -K should c ontain the information
required by Item 2.01(f) of Form 8 -K and the related financial information required by Item
9.01 of Form 8 -K for Sampo IP LLC, including pro forma financial information.  See Rules
8-04 and 8 -05 of Regulation S -X.  Please amend both filings accordingly.

4. Please refer to comment 6 in our November 5, 2012 letter.  As requested previously, update
your EDGAR company profile to include your current business address, telephone number,
e-mail address, and mailing address.

Closing

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
the filing s to be certain that the filing s include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  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 provide a written statement from the company
acknowledging that:

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

 Staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to t he filing s.

Mr. Mark Groussman
American Strategic Minerals Corporation
November 27, 2012
Page 3

 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 disclosure issues to Edward M.  Kelly  at 202-
551-3728 or Craig E. Slivka  at (202) 551 -3729.

Very truly yours ,

       /s/  Craig E. Slivka, for

Pamela A. Long
Assistant Director

cc: Via E-mail
 Harvey J. Kesner,  Esq.
 Sichenzia Ross Friedman Ference LLP
 61 Broadway, 32nd Floor
 New York, NY 10006