SecProbe.io

May 10, 2013

Via U.S. Mail
Mr. Danny Aaron
President
Oro Capital Corporation, Inc.
23 Dassan Island Drive
Plettenberg Bay, 6600
South Africa

Re: Oro Capital Corporation, Inc.
Amendment No. 2 to Registration Statement on Form S -1
Filed April 30 , 2013
  File No. 333-185103

Dear Mr. Aaron :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not bel ieve an amendment is appropriate, please tell us why in your
response.

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

Summary, page 4

1. Pleas e revise here and under your Plan of Distribution to clarify (1) who will offer the
shares on behalf of the company, (2) the applicability of any exemptions claimed, and (3)
if and how they will be compensated, based on your current intentions.  To the ext ent that
you are reserving the ability to change your plan of distribution, such as paying
compensation to other parties, revise to clarify and acknowledge your understanding of
Item 512(a)(1)(iii) of Regulation S -K.

2. Please revise the discussion of phases  on page six, MD&A and where appropriate to
discuss your plans for obtaining funds to conduct exploration activities.  For example, it
appears that you will require significant capital to move to and complete phase three even

Danny Aaron
Oro Capital Corporation, Inc.
May 10, 2013
Page 2

 if you sell all of the shares in this offering.  And it appears that if you sell 50% or fewer
of the shares you will not be able to complete or, depending on the proceeds, merely start
phase one.  Please revise accordingly.

Risk Factors, page 9

3. The revised disclosure on page 11 indicates that Mr. Aaron has agreed to advance monies
to you.  Please file this agreement and summarize the material terms in an appropriate
location, such as your Management’s Discussion and Analysis.

Management’s Discussion and Analysis of Financial Con dition and Results of Operations, page
16

4. In your revised text on page 16 you indicate that you will not begin exploration until you
raise funds from this offering.  Please quantify the amount of funds you will need to
commence exploration.  We also note your statement that you believe you will need to
raise $40,000 from the offering “in order to remove uncertainties surround [y]our ability
to continue as a going concern.”  Please include this statement in your Summary and
clarify the implications to inves tors if you sell less than all of the offered shares and are
otherwise unable to raise funds.

5. We reissue prior comment eight from our letter dated March 5, 2013.  Please review the
requirements of Item 303 of Regulation S -K and revise as appropriate.  For  example your
revised disclosure should address your liquidity and capital resources and discuss
changes in your cash flows in greater detail.

6. We note your disclosure on page 16 that if you raise the maximum amount of
proceeds from this offering, it wil l last a year.   However, we also note your
disclosure on page 17 that even if all shares are sold in this offering you may not
have sufficient available cash in order to maintain operations during the next twelve
months.   Please clarify and revise to inclu de consistent disclosures throughout the
filing.

Certain Transactions with Officers and Directors, page 25

7. Please separately disclose the amounts paid to Mr. Aaron for rent and services during
each required period.  Also, to the extent that you have on -going arrangements to pay Mr.
Aaron for these or other items, revise to discuss the material terms.

Danny Aaron
Oro Capital Corporation, Inc.
May 10, 2013
Page 3

 Dilution

If 100% of the Shares are Sold, page 26

8. We note your disclosure here that upon completion of the offering, the pro forma net
tangible book value of the 6,000,000 shares will be $26,206 or $0.004 per share.   It
appears to us that if 100% of the shares are sold, pro forma net tangible book value
upon completion of the offering would be $7,793 or $0.00 per share. Please revise or
advise.

Description of Business, page 29

9. The table added on page 32 in response to prior comment 20 refers to “[m]onths from
completing our public offering.”   Please c larify when your public offering will be
deemed completed.

Exhibits

Exhibit 5.1

10. We partially reissue prior comment 25 from our letter dated March 5, 2013.  Please delete
the language that Mr. Barkley is licensed “only in the State of North Carolina.”   For
additional guidance, please consider Staff Legal Bulletin No. 19 (October 14, 2011),
Section B.3.b.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the inform ation the Securities Act of 193 3 and
all applicable Securities  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  they have made.

You may contact Raj Rajan  at (202) 551 -3388  or Brian Bhandari  at (202) 551 -3390  if
you have questions regarding comments on the financial statements and related matters.  If you
have questions concerning engineering -related matters, ple ase contact Ken Schuler at (202) 551 -
3718.  Please contact Jay Williamson at (202) 551 -3393  or Jim Lopez at (202) 551 -3536  with
any other questions.

Sincerely,

 /s/ Pamela Howell
 for

John Reynolds
Assistant Directo r