SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

         January 16 , 2013

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
  Amendment 1 to Current Report on Form 8 -K
  Filed December 26 , 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 filin g, 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 y our 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 revised disclaimer that you cannot assure inve stors of the accuracy or
completeness of “data related to market and industry statistics based on third party
publications” included in the Form 8 -K.  As noted previously, you may not disclaim
responsibility for information that you have chosen to include in the Form 8 -K.  Please delete
the disclaimer.

Description of Sampo’s Business, page 4

2. We note your response to comment four of our letter dated December 18, 2012.  Please tell

Mr. Douglas Croxall
American Strategic Minerals Corporation
January 16, 2013
Page 2

 us and disclose clearly whether prior to the transaction with Sampo the registrant ever
generated revenue from operations or engaged in business operations beyond the
development stage.  Please provide details of those activities.

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 a dequacy 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 comme nts 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 pers on 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