SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

        Dece mber 18, 2012

Via E-mail
Mr. Douglas Croxall
Chief Executive Officer  and Chairman
American Strategic Minerals Corporation
2331 Mill Road, Suite 100
Alexandria, VA 22314

 Re: American Strategic Minerals Corporation
  Current Report on Form 8 -K
  Filed November 20 , 201 2
  File No. 0-54652

Dear Mr. Croxall :

We have reviewed your 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 advising us when you will provide 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.

Forward -Looking Statements, page 1

1. We note the disclaimer that you cannot assure investors of the accuracy or completeness of
the data included in the Form 8 -K.  Since you may not  disclaim responsibility for information
that you have chosen to include in the Form 8 -K, please delete the disclaimer.

Completion of Acquisition or Disposition of Assets, page 1

2. Disclose the monetary value of the 9,250,000 shares of common stock issued in the share
exchange.

Mr. Douglas Croxall
American Strategic Minerals Corporation
December 18 , 2012
Page 2

 3. Disclose what the life of Sampo’s patent rights is.
Description of Sampo’s Business, page 4

4. The presentation under “General” and “Business Model and Strategy – Overview” suggests
or implies that Sampo  is a fully operational company rather than a development stage
company.  As appropriate, revise these subsections to present information accurately and
adequately on Sampo as a development stage company (or simply an entity possessing
intellectual propert y rights) rather than as a fully operational company.  Please also provide
us a supplemental explanation of your belief that at the time of the transaction with Sampo,
you were not a shell company.

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 re sponsible 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 the filing s.

 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.

Mr. Douglas Croxall
American Strategic Minerals Corporation
December 18 , 2012
Page 3

 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