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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
  Preliminary Proxy Statement on Schedule 14A
  Filed December 21 , 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.

General

1. We note that the preliminary proxy statement on Schedule 14A which was filed on Decem ber
21, 2012 is to amend the company’s articles of incorporation to change the company’s name
to Marathon Patent Group, Inc. because the board of directors determined that the name
better reflects the company’s long term strategy, identity, and new busines s direction.
Disclose what the company’s long term strategy and new business direction are.  Further,
disclose what comprise the company’s assets for its long term strategy and new business
direction.

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

 2. We note that the preliminary proxy statement on Sched ule 14A which was filed on December
21, 2012 also is to authorize the board of directors to amend the company’s articles of
incorporation to effect a two for three reverse split of the company’s common stock.
Because the reverse split will decrease the nu mber of issued and outstanding shares of
common stock and increase the number of shares of common stock available for issuance,
disclose whether the company has any plans, proposals, or understandings, formally or
informally, to issue any of the additional  shares of common stock that would be available
after the reverse split is effected.

3. For notice and timing of a reverse stock split, we direct your attention to the requirements of
Rule 10b -17 under the Exchange Act.

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 the filing s.

 The co mpany 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

Mr. Douglas Croxall
American Strategic Minerals Corporation
January 16, 2013
Page 3

 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