SecProbe.io

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 March 26, 2026

Reginald Fubara
Chief Executive Officer
HyOrc Corporation
3050 Post Oak Boulevard, Suite 510-Q60
Houston, TX 77056

 Re: HyOrc Corporation
 Registration Statement on Form 10-12G
 Filed September 22, 2025
 File No. 000-51048
Dear Reginald Fubara:

 We have completed our review of your filing. We remind you that the
company and its
management are responsible for the accuracy and adequacy of their disclosures,
notwithstanding
any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Reginald L. Sewell
</TEXT>
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 March 19, 2026

Reginald Fubara
Chief Executive Officer
HyOrc Corporation
3050 Post Oak Boulevard, Suite 510-Q60
Houston, TX 77056

 Re: HyOrc Corporation
 Amendment No. 4 to Registration Statement on Form 10
 Filed February 25, 2026
 File No. 000-51048
Dear Reginald Fubara:

 We have reviewed your filing and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe the
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Amendment No. 4 to Registration Statement on Form 10
General

1. Please revise to include the disclosure required by Items 6, 7, 9, and
10 of Form 10, or
 include disclosure that the relevant Items are not applicable and the
basis for such
 statement. With respect to Item 6. Executive Compensation, please revise
to include such
 information for your last fiscal year ended December 31, 2025. Refer to
Item 402 of
 Regulation S-K.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
 March 19, 2026
Page 2

 Please contact Suying Li at 202-551-3335 or Angela Lumley at
202-551-3398 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Reginald L. Sewell
</TEXT>
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CORRESP
 1
 filename1.htm

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Trade & Services

 Washington,
D.C. 20549

 VIA
EDGAR

 Wednesday,
25 February 2026

 Response
to Comments of the Staff of the Division of Corporation Finance

 Registration
Statement on Form 10

 Filed
December 31, 2025

 File
No. 000-51048

 Dear
Sir or Madam,

 On
behalf of HyOrc Corporation (the "Company"), we hereby respond to the comments of the Staff of the Division of Corporation
Finance (the "Staff") set forth in the Staff's letter dated February 18, 2026 (the "Comment Letter") relating
to the above-referenced Registration Statement on Form 10.

 Concurrently
with this letter, the Company is filing an Amendment to the Registration Statement (the "Amended Form 10"), which reflects
revisions made in response to the Staff's comments. For the Staff's convenience, each comment is reproduced below in bold,
followed by the Company's response.

 Comment
1:

 Please
revise to state clearly here and on page 14, if true, that you are not currently generating revenue under the Joint Venture Agreement
with Start Lda and that Phase 1 of the project may not be operational until July 2026 or later.

 Response:

 The
Company has revised the disclosure on pages 4 and 14 of the Amended Form 10 to clarify that (i) the Company is not currently generating
revenue under the Joint Venture Agreement with Start Lda and (ii) Phase 1 of the green methanol pilot facility may not become operational
until July 2026 or later, subject to customary development risks including permitting, financing, equipment delivery, installation and
commissioning.

 Comment
2:

 Please
revise your disclosure to clarify that you do not operate facilities in India but instead conduct limited operations through services
provided by Vaigunth Enertek, and further clarify the nature of your partnership, including whether the arrangement is covered by an
agreement.

 Response:

 The
Company has revised the disclosure in Item 3 – Properties to clarify that it does not own, lease, or operate facilities in India.
The Amended Form 10 now explains that engineering, fabrication, prototyping, and related services are performed by Vaigunth Enertek,
an independent third-party service provider, pursuant to a services agreement. The revised disclosure clarifies that the Company does
not control Vaigunth Enertek's facilities or operations and does not hold any ownership interest therein.

 Comment
3:

 Staff
Comment

 Item
15. Financial Statements and Exhibits (b) Exhibits 5.0 - Audited Financial Statements for 2023 & 2024, page 23

 Your
disclosure of the purchase price allocation on page 18 of the exhibit indicates that substantially all of the fair value of the gross
assets acquired is concentrated in customer relationship, a single identifiable asset, or group of similar identifiable assets. Please
tell us your consideration of the screen test provided in paragraphs ASC 805-10-55-5A through 55-5C in determining that ASPZ (now HyOrc)
could be deemed a business.

 Company
Response

 The
Company respectfully advises the Staff that it evaluated the acquired set in accordance with ASC 805-10-55-3A through 55-9, including
application of the optional concentration (screen) test under ASC 805-10-55-5A through 55-5C.

 ASC
Framework

 ASC
805-10-55-5A provides that if substantially all of the fair value of the gross assets acquired is concentrated in a single identifiable
asset or group of similar identifiable assets, the acquired set is not a business.

 ASC
805-10-55-5B and 55-5C provide guidance for determining:

 ● What constitutes a single identifiable asset

 ● What constitutes
a group of similar identifiable assets

 ● Whether identifiable assets are similar in nature and risk characteristics

 Evaluation
of Gross Assets

 Management
evaluated the fair value of the gross assets acquired as of the acquisition date in accordance with ASC 805-10-55-5A.

 The
gross assets acquired consisted of:

 ● Customer relationship intangible assets

 ● Development-stage mineral project interests

 ● Contractual rights and negotiation positions

 ● Technical due diligence and feasibility documentation

 ● Organizational infrastructure

 ● Operational know-how and proprietary evaluation methodologies

 Although
a significant portion of the purchase price allocation was attributed to customer relationship intangible assets, management determined
that substantially all of the fair value was not concentrated in a single identifiable asset or group of similar identifiable assets.

 Determination
That Assets Were Not Similar

 In
evaluating similarity under ASC 805-10-55-5B through 55-5C, management considered the nature and risk characteristics of each asset category.

 The
Company concluded that:

 ● Customer relationship intangible assets represent rights to economic benefits derived
from established counterparties and are subject primarily to counterparty and market demand risk.

 ● Development-stage mineral project interests represent rights in underlying mineral
opportunities subject to geological, regulatory, permitting, and commodity price risk.

 ● Contractual negotiation rights represent legally enforceable strategic positions distinct
from customer-related assets.

 ● Technical documentation and feasibility analyses represent structured intellectual
capital used in project evaluation.

 ● Organizational infrastructure and operational know-how reflect embedded capabilities
and structured operational methodologies.

 These
assets differ in their economic characteristics, risk exposure, and function. Accordingly, they do not constitute a single identifiable
asset or a group of similar identifiable assets within the meaning of ASC 805-10-55-5B and 55-5C.

 Based
on this analysis, management concluded that the optional concentration test in ASC 805-10-55-5A was not met. Therefore, further evaluation
under the business definition guidance was required.

 Staff
Comment

 Item
15. Financial Statements and Exhibits (b) Exhibits 5.0 - Audited Financial Statements for 2023 & 2024, page 23

 You
state that ASPZ pursued mineral-related initiatives and the performance of due diligence and evaluation activities constituted substantive
processes essential to developing a revenue-generating operation. Please describe your business inputs and substantive process in greater
detail. Tell us whether your process includes employees that form an organized workforce with the necessary skills, knowledge or experience
to perform the process. Refer to ASC 805-10-55-5D

 Company
Response

 The
Company respectfully advises the Staff that, having concluded the screen test was not met, it evaluated whether the acquired set met
the definition of a business under ASC 805-10-55-3A through 55-9.

 ASC
Framework

 ASC
805-10-55-3A defines a business as an integrated set of activities and assets that includes, at a minimum:

 ● An input; and

 ● A substantive process that together significantly contribute to the ability to create outputs.

 ASC
805-10-55-4 clarifies that outputs are not required for a set to qualify as a business.

 ASC
805-10-55-5 through 55-6 and 55-8 through 55-9 provide guidance on evaluating whether a process is substantive, particularly when a set
does not yet have outputs.

 ASC
805-10-55-5D states that when a set does not have outputs, a substantive process generally requires an organized workforce with the necessary
skills, knowledge, or experience to perform the process.

 Identified
Inputs

 At
the acquisition date, ASPZ possessed the following inputs:

 ● Development-stage mineral project interests

 ● Geological studies and technical evaluation reports

 ● Economic feasibility models

 ● Contractual rights and negotiation positions

 ● Strategic development plans

 ● Capital resources allocated to advancing mineral-related opportunities

 These
inputs are consistent with the examples in ASC 805-10-55-4, which include intellectual property, rights, and other economic resources
capable of generating outputs when combined with processes.

 Substantive
Processes

 ASPZ's
processes were structured and ongoing and included:

 ● Technical evaluation of mineral opportunities

 ● Resource assessment and geological analysis

 ● Economic feasibility modeling and capital allocation analysis

 ● Negotiation of development arrangements

 ● Strategic planning activities designed to advance projects toward potential revenue generation

 Management
determined that these processes were substantive because they:

 ● Required specialized technical and financial expertise

 ● Involved structured analytical methodologies

 ● Were directed toward converting mineral interests into revenue-producing operations

 ● Were critical to advancing the development-stage initiatives

 These
activities were not administrative or clerical in nature but instead constituted essential value-generating processes.

 Organized
Workforce

 At
the acquisition date, ASPZ utilized personnel with relevant experience in mineral project evaluation, financial modeling, and strategic
development.

 These
individuals:

 ● Performed the technical and financial analyses described above

 ● Conducted due diligence and evaluation activities

 ● Participated in negotiation and strategic planning efforts

 Management
concluded that these individuals constituted an organized workforce possessing the necessary knowledge and experience to perform the
substantive processes described above, as contemplated by ASC 805-10-55-5D.

 Conclusion

 Based
on:

 ● The presence of identifiable inputs;

 ● The existence of substantive processes applied to those inputs; and

 ● The presence of an organized workforce performing those processes;

 The
Company concluded that the acquired set met the definition of a business under ASC 805-10-55-3A and that business combination accounting
was appropriate.

 Comment
4:

 Please
revise your filing to provide the results of operations and cash flow discussions for the interim period ended September 30, 2025 in
the MD&A section pursuant to Item 303 of Regulation S-K.

 Response:

 The
Company has revised Item 2 – Management's Discussion and Analysis in the Amended Form 10 to include a discussion of results
of operations, liquidity, and cash flows for the nine months and three months ended September 30, 2025, including comparative analysis
to the corresponding 2024 periods, in compliance with Item 303 of Regulation S-K.

 The
Company respectfully submits that the revisions contained in the Amended Form 10 address the Staff's comments. We appreciate the
Staff's time and attention in reviewing the Registration Statement.

 If
you have any further questions or comments, please do not hesitate to contact the undersigned.

 Sincerely,

 /s/
K. Reginald Fubara

 K.
Reginald Fubara

 Chief
Executive Officer

 HyOrc
Corporation

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 February 18, 2026

Reginald Fubara
Chief Executive Officer
HyOrc Corporation
3050 Post Oak Boulevard, Suite 510-Q60
Houston, TX 77056

 Re: HyOrc Corporation
 Amendment No. 3 to Registration Statement on Form 10
 Filed December 31, 2025
 File No. 000-51048
Dear Reginald Fubara:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response and any amendment you may file in response
to this letter,
we may have additional comments.

Amendment No. 3 to Registration Statement on Form 10-12G
Item 1. Business
Principal Business Lines
1. Green Methanol Production, page 4

1. Please revise to state clearly here and on page 14, if true, that you
are not currently
 generating revenue under the Joint Venture Agreement with Start Lda and
that Phase 1 of
 the project may not be operational until July 2026 or later.
Item 3. Properties, page 13

2. We note your response to prior comment 3 and that your relationship with
Vaigunth
 Enertek consists of fabrication and testing, engineering and R&D
support, and limited
 manufacturing services in their facilities. We also note your disclosure
that "[t]hrough
 SRE Power and technology partner Vaigunth Enertek, we operate
engineering and
 prototyping facilities in India." Please revise your disclosure to
clarify, if true, that you
 do not operate facilities in India, but instead conduct the limited
operations listed above
 through the services provided by Vaigunth Entertek. Please also further
clarify the nature
 February 18, 2026
Page 2

 of your partnership with Vaigunth Enertek, including whether the
arrangement is covered
 by an agreement. If so, please provide a description of the material
terms of the
 agreement and file the agreement as an exhibit to the registration
statement. Refer to
 Item 601(b)(10) of Regulation S-K.
Item 15. Financial Statements and Exhibits
(b) Exhibits
5.0 - Audited Financial Statements for 2023 & 2024, page 23

3. We note your response to prior comment 7. Please address the following:
 Your disclosure of the purchase price allocation on page 18 of the
exhibit indicates
 that substantially all of the fair value of the gross assets acquired
is concentrated
 in customer relationship, a single identifiable asset, or group of
similar identifiable
 assets. Please tell us your consideration of the screen test provided
in paragraphs
 ASC 805-10-55-5A through 55-5C in determining that ASPZ (now HyOrc)
could be
 deemed a business.
 You state that ASPZ pursued mineral-related initiatives and the
performance of due
 diligence and evaluation activities constituted substantive processes
essential to
 developing a revenue-generating operation. Please describe your
business inputs and
 substantive process in greater detail. Tell us whether your process
includes
 employees that form an organized workforce with the necessary skills,
knowledge or
 experience to perform the process. Refer to ASC 805-10-55-5D.
6.0 - Unaudited Interim Financial Statements for September 2025, page 23

4. We note your response to prior comment 1. However, we were not able to
locate your
 results of operations and cash flow discussions for the interim period
ended September
 30, 2025 in the MD&A section. Please revise your filing to provide the
information
 required in Item 303 of Regulation S-K.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

 Please contact Suying Li at 202-551-3335 or Angela Lumley at
202-551-3398 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Reginald L. Sewell
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Monday,
29 December 2025

 Response
to Comments of the Staff of the Division of Corporation Finance
Registration Statement on Form 10
File No. 000-51048

 Dear
Sir or Madam:

 HyOrc
Corporation (the "Company," "HyOrc," "we," or "us") respectfully submits the following
responses to the comments of the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the "Staff")
contained in the Staff's comment letter. Concurrently with this response, the Company has filed an amendment to its Registration
Statement on Form 10 (the "Amended Form 10").

 Comment
1:

 Unaudited
Interim Financial Statements, page 1

 Staff
Comment

 1.
Please revise your interim financial statements to include your balance sheet as of December 31, 2024 and the unaudited financial
statements for the comparable interim period of the preceding fiscal year. Refer to Rule 10-01(c) of Regulation S-X. In addition,
please provide your liquidity and results of operations discussions for the interim period ended September 30, 2025, in your
MD&A section. Refer to Item 303 of Regulation S-K.

 Company
Response

 The
Company has addressed the Staff's comment by filing an amendment to the Form 10 that includes unaudited interim consolidated financial
statements for the period ended September 30, 2025, together with comparative unaudited interim consolidated financial statements for
the period ended September 30, 2024.

 The
Amended Form 10 includes:

 ● Consolidated
 balance sheets as of September 30, 2025, and December 31, 2024

 ● Consolidated
 statements of operations and comprehensive loss for the three- and nine-month periods ended
 September 30, 2025, and 2024

 ● Consolidated
 statements of stockholders' equity and cash flows for the same periods

 Management's
Discussion and Analysis has been updated to include a discussion of liquidity and capital resources, interim operating results, period-over-period
changes, and known uncertainties affecting revenue generation during the interim period.

 These
interim financial statements supersede the previously filed June 30, 2025, interim financial information, which is no longer current.

 Comment
2:

 Item
1. Business, page 2

 Staff
Comment

 2.
Please revise your disclosure here and throughout the registration statement, including in your MD&A section, to more clearly
articulate the status of your operations, any revenue-generating activity, and current customers. To the extent your pilot projects
have generated revenue, please revise to state as much. We note that you had no revenue for the year ended December 31, 2023 and
$617,115 of revenue for the year ended December 31, 2024, comprised of the O&M and technical services provided to BGI. Please
revise this section to clearly disclose your current operations, elaborating on your description of the operation and maintenance
and technical support services rendered to BGI as well as the related fee structure and clearly distinguish any portion of your
operations that are aspirational at this time. Refer to Item 101 of Regulation SK. In this regard, we note your disclosure on page
F-12 regarding the PFBT Agreement with BGI. Please revise your Business section to include a similar description of the agreement
and file the agreement as an exhibit to the registration statement. Refer to Item 601(b)(10) of Regulation S-K. Additionally, please
revise your risk factor disclosure to address the related material risks.

 Company
Response

 The
Amended Form 10 clarifies the Company's operations by delineating its activities into three integrated business areas:

 1. Development
 of waste-to-methanol, hydrogen, and clean-fuel infrastructure projects

 2. Commercialization
 of external-combustion and multi-fuel engine technology

 3. Existing
 revenue-generating operations conducted through SRE Power, Inc.

 Revenue
and customers

 For
fiscal year 2024, the Company generated revenue primarily from operation and maintenance services, electricity sales, and technical services
provided through its subsidiary SRE Power, Inc. under the Project Funding, Build and Transfer ("PFBT") Agreement with Biliran
Geothermal, Inc. ("BGI").

 As
of September 30, 2025, the Biliran 2 MW geothermal power plant was temporarily offline due to an ongoing legal dispute between SRE Power
and BGI. SRE Power is pursuing a recovery and enforcement strategy with external legal counsel. As a result, no material revenue was
recognized during the 2025 interim period. This operational status and its impact on revenue are disclosed in the Amended Form 10 and
reconciled to prior-year revenue.

 BGI
/ PFBT Agreement

 The
PFBT Agreement is a 25-year contract under which SRE Power finances, builds, commissions, and operates geothermal power facilities for
BGI, beginning with a 2 MW module commissioned in 2023. Revenue under the agreement consists of:

 ● Operation
 and maintenance fees

 ● Technical
 services fees

 ● A
 contractual share of electricity generation revenues

 The
PFBT Agreement is material to the Company and has been filed as an exhibit to the Amended Form 10.

 Development-stage
activities

 Projects
relating to hydrogen locomotives, green methanol, waste-to-syngas, and future engine deployments are identified as development-stage
initiatives unless and until binding commercial agreements are executed.

 Risk
factors

 The
Amended Form 10 includes expanded risk factor disclosure addressing, among other things, revenue interruption risk arising from contractual
disputes, counterparty enforcement risk, customer concentration risk, and execution and financing risks associated with development-stage
projects.

 Comment
3:

 Item
3. Properties, page 12

 Staff
Comment

 3.
We note your disclosure stating that "[t]hrough SRE Power and technology partner Vaigunth Enertek, we operate engineering and prototyping
facilities in India ... ." Please expand your disclosure to clarify the relationship between the subsidiary and Vaigunth Enertek,
including whether there are any material agreements and their terms. Please also disclose whether you derive any revenue from these facilities.

 Company
Response

 Vaigunth
Enertek is an independent engineering and fabrication company in India that provides fabrication, prototyping, testing, and engineering
support services to SRE Power on a non-exclusive, fee-for-service basis; the Company does not own or lease Vaigunth Enertek's facilities
and does not derive revenue from their operation.

 Through
SRE Power and technology partner Vaigunth Enertek, we operate engineering and prototyping facilities in India, focused on waste-to-energy,
hydrogen engine development and ORC systems.

 Vaigunth
Enertek is an independent engineering and fabrication company located in India that has historically provided manufacturing, prototyping,
testing, and engineering support services to SRE Power and its affiliates.

 HyOrc
does not own or lease Vaigunth Enertek's facilities. The relationship consists of:

 ● Fabrication
 and testing of prototype components

 ● Engineering
 and R&D support

 ● Limited
 manufacturing services conducted on a cost basis

 HyOrc
does not derive revenue from the operation of Vaigunth Enertek's facilities, nor are those facilities considered Company-owned
properties.

 Comment
4:

 Item
5. Directors and Executive Officers, page 13

 Staff
Comment

 4.
Please revise the biographies of your directors and officers to clarify their principal occupation and employment during the past
five years, including the name and principal business of any corporation or other organization. Please also revise to indicate any
directorships held by each director in the last five years in other companies and name such companies. Refer to Item 401(e) of
Regulation S-K.

 Company
Response

 The
Amended Form 10 includes expanded biographical disclosure for directors and executive officers and complies with Item 401(e) of Regulation
S-K, including principal occupations and relevant experience.

 Comment
5

 Item
15. Financial Statements and Exhibits

 Staff
Comment

 (b)
Exhibits, page 19

 5.
We note that Exhibits 1.1 and 1.2, the Articles of Incorporation and Bylaws of the company, respectively, appear to be dated and/or certified
as of April 6, 1998. Please revise to include the Articles of Incorporation and Bylaws that are currently in effect and any amendments
thereto. Refer to Item 601(b)(3)(ii) and (ii) of Regulation S-K.

 Company
Response

 The
Amended Form 10 includes the Company's currently effective Articles of Incorporation and Bylaws, including all amendments in effect
as of the filing date. Outdated charter documents have been removed.

 Comment
6:

 Consolidated
Financial Statements December 31, 2024 and 2023, page F-1

 Staff
Comment

 6.
We note that you have filed both annual and interim financial statements as part of your requirements to trade on the OTC market. These
filed financial statements appear to be inconsistent with the financial statements filed in the Form 10 for the year ended December 31,
2024 and the interim period ended September 30, 2025.

 Please
clarify or revise.

 Company
Response

 Differences
between prior financial information posted on OTC Markets and the financial statements included in the Form 10 arise from the application
of reverse-acquisition accounting under ASC 805-40, audit adjustments, and presentation refinements. The Company considers the Form 10,
as amended, to be its authoritative financial disclosure, and OTC disclosures will be conformed accordingly.

 Comment
7:

 Note
3. Reverse Acquisition, page F-17

 Staff
Comment

 Please
tell us how you determined that ASPZ met the definition of a business in ASC 805-10-55-3A through 55-9. If ASPZ did not meet the definition
of a business, please tell us how you considered the guidance in ASC 805-40-25-1 in accounting for the SRE acquisition as a reverse acquisition.

 Company
Response

 We
respectfully submit the following response to the Staff of the U.S. Securities and Exchange Commission.

 Immediately
prior to the SRE transaction, Asia Properties, Inc. ("ASPZ") was a development-stage public company that established an organized
operating framework to identify, evaluate, structure, and execute business initiatives. During 2021 and subsequent periods, ASPZ undertook
a series of deliberate actions directed toward implementing its business strategy, including strategic planning, organizational structuring,
asset identification, evaluation activities, and transaction execution efforts. Although certain initiatives were in planning or early
execution stages and had not yet resulted in recurring operating revenues, these actions reflected active business operations rather
than mere asset holding.

 As
part of this strategic repositioning, ASPZ pursued mineral-related initiatives through an affiliate LLC. This represented an intentional
organizational step to segregate and manage a defined line of business and to facilitate evaluation of mineral-related opportunities.
Through this, ASPZ initiated legal, commercial, and structural due diligence activities in connection with potential mineral exploration
and mining lease opportunities. These activities included evaluating potential projects, assessing feasibility, and engaging with third
parties. While these initiatives had not yet advanced to commercial production, the performance of due diligence and evaluation activities
constituted substantive processes essential to developing a revenue-generating operation.

 During
this period, ASPZ also evaluated the acquisition of a specialized gold asset (the "Bering Sea Clinker") in connection with
its broader mineral-related strategy. Following the acquisition, management evaluated potential monetization pathways and structuring
alternatives for the asset. The acquisition of the asset itself constituted an input under ASC 805, while the related evaluation and
structuring activities reflected organized commercialization planning processes. Importantly, management's conclusion that ASPZ
met the definition of a business does not depend on the ultimate success or execution of these mineral-related initiatives, but rather
on the existence of inputs and substantive processes directed toward producing future economic outputs.

 In
addition to mineral-related activities, ASPZ maintained ongoing strategic planning, transaction structuring, and capital-raising processes.
As a public OTC-listed company, ASPZ had established governance, financial reporting, regulatory compliance, and disclosure processes
that supported management oversight and execution of its business plans. ASPZ actively evaluated and also is in the process of evaluating
financing alternatives, capital requirements, and transaction structures necessary to advance identified initiatives. ASC 805-10-55-6
through 55-8 acknowledge that substantive processes may exist even where activities are performed by a limited workforce or through external
advisors, particularly for development-stage entities, provided such processes are critical to the ability to develop and manage the
business.

 Although
ASPZ had not yet generated recurring operating revenues prior to the SRE transaction, ASC 805-10-55-3A explicitly states that outputs
are not required for an acquired set to qualify as a business if it includes inputs and substantive processes that together have the
ability to produce outputs. Management concluded that ASPZ's organized inputs, including its corporate structure, identified assets,
and access to capital, when applied through the substantive processes described above, namely strategic planning, due diligence, transaction
execution, asset monetization planning, financing, and governance, provided ASPZ with the ability to produce outputs.

 Based
on the foregoing, management determined that immediately prior to the SRE transaction, ASPZ possessed identifiable inputs and had implemented
organized and substantive business processes within the meaning of ASC 805-10-55-3A through 55-9, and that those inputs and processes
together provided ASPZ with the ability to produce outputs. Accordingly, ASPZ met the definition of a business under ASC 805.

 Having
concluded that ASPZ met the definition of a business, management evaluated the transaction under the reverse acquisition guidance in
ASC 805-40. Although ASPZ was the legal acquirer as it issued equity instruments, SRE was identified as the accounting acquirer based
on the indicators in ASC 805-40-25-2 through 25-6, including:

 ●
Former shareholders of SRE obtained approximately 90% of the voting interest in the combined entity.

 ●
The former owners of SRE retained control over the governing body and decision-making of the combined entity.

 ●
The relative size and operational substance of SRE compared to ASPZ indicated that SRE was the dominant operating entity.

 Accordingly,
the transaction was accounted for as a reverse acquisition, with SRE identified as the accounting acquirer and ASPZ as the accounting
acquiree, consistent with ASC 805-40-25-1.

 Comment
8:

 Note
5. Intangible Assets, page F-19

 Staff
Comment

 Please
provide the information required in ASC 350-30-50-1 for the patents recorded in 2024 and the disclosure required in ASC 350-30-50-3 for
the impairment loss recorded in 2024.

 Company
Response

 We
respectfully submit the following response to the Staff of the U.S. Securities and Exchange Commission.

 The
Company respectfully advises the Staff that the patents recorded in 2024 are classified as indefinite-lived intangible assets in accordance
with ASC 350-30. As disclosed in Note 5, management determined that the patents are expected to contribute to cash flows indefinitely
and that the associated renewal costs are not significant. Accordingly, the patents are not amortized, and the disclosure requirements
in ASC 350-30-50-1, which apply to finite-lived intangible assets, are

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<TEXT>
 December 23, 2025

Reginald Fubara
Chief Executive Officer
HyOrc Corporation
3050 Post Oak Boulevard, Suite 510-Q60
Houston, TX 77056

 Re: HyOrc Corporation
 Registration Statement on Form 10
 Filed September 22, 2025
 Amendment No. 1 to Registration Statement on Form 10
 Filed October 8, 2025
 Amendment No. 2 to Registration Statement on Form 10
 Filed November 19, 2025
 File No. 000-51048
Dear Reginald Fubara:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response and any amendment you may file in
response to this
letter, we may have additional comments.

Registration Statement on Form 10-12G
Unaudited Interim Financial Statements, page 1

1. Please revise your interim financial statements to include your balance
sheet as of
 December 31, 2024 and the unaudited financial statements for the
comparable interim
 period of the preceding fiscal year. Refer to Rule 10-01(c) of
Regulation S-X. In
 addition, please provide your liquidity and results of operations
discussions for the
 interim period ended September 30, 2025 in your MD&A section. Refer to
Item 303
 of Regulation S-K.
 December 23, 2025
Page 2
Item 1. Business, page 2

2. Please revise your disclosure here and throughout the registration
statement, including
 in your MD&A section, to more clearly articulate the status of your
operations, any
 revenue-generating activity, and current customers. To the extent your
pilot projects
 have generated revenue, please revise to state as much. We note that you
had no
 revenue for the year ended December 31, 2023 and $617,115 of revenue for
the year
 ended December 31, 2024, comprised of the O&M and technical services
provided to
 BGI. Please revise this section to clearly disclose your current
operations, elaborating
 on your description of the operation and maintenance and technical
support services
 rendered to BGI as well as the related fee structure and clearly
distinguish any portion
 of your operations that are aspirational at this time. Refer to Item 101
of Regulation S-
 K. In this regard, we note your disclosure on page F-12 regarding the
PFBT
 Agreement with BGI. Please revise your Business section to include a
similar
 description of the agreement and file the agreement as an exhibit to the
registration
 statement. Refer to Item 601(b)(10) of Regulation S-K. Additionally,
please revise
 your risk factor disclosure to address the related material risks.
Item 3. Properties, page 12

3. We note your disclosure stating that "[t]hrough SRE Power and technology
partner
 Vaigunth Enertek, we operate engineering and prototyping facilities in
India ... ."
 Please expand your disclosure to clarify the relationship between the
subsidiary and
 Vaigunth Enertek, including whether there are any material agreements
and their
 terms. Please also disclose whether you derive any revenue from these
facilities.
Item 5. Directors and Executive Officers, page 13

4. Please revise the biographies of your directors and officers to clarify
their principal
 occupation and employment during the past five years, including the name
and
 principal business of any corporation or other organization. Please also
revise to
 indicate any directorships held by each director in the last five years
in other
 companies and name such companies. Refer to Item 401(e) of Regulation
S-K.
Item 15. Financial Statements and Exhibits
(b) Exhibits, page 19

5. We note that Exhibits 1.1 and 1.2, the Articles of Incorporation and
Bylaws of the
 company, respectively, appear to be dated and/or certified as of April
6, 1998. Please
 revise to include the Articles of Incorporation and Bylaws that are
currently in effect
 and any amendments thereto. Refer to Item 601(b)(3)(ii) and (ii) of
Regulation S-K.
Consolidated Financial Statements December 31, 2024 and 2023, page F-1

6. We note that you have filed both annual and interim financial statements
as part of
 your requirements to trade on the OTC market. These filed financial
statements
 appear to be inconsistent with the financial statements filed in the
Form 10 for the
 year ended December 31, 2024 and the interim period ended September 30,
2025.
 Please clarify or revise.
 December 23, 2025
Page 3
Notes to the Consolidated Financial Statements
Note 3. Reverse Acquisition, page F-17

7. Please tell us how you determined that ASPZ met the definition of a
business in ASC
 805-10-55-3A through 55-9. If ASPZ did not meet the definition of a
business, please
 tell us how you considered the guidance in ASC 805-40-25-1 in accounting
for the
 SRE acquisition as a reverse acquisition.
Note 5. Intangible Assets, page F-19

8. Please provide the information required in ASC 350-30-50-1 for the
patents recorded
 in 2024 and the disclosure required in ASC 350-30-50-3 for the
impairment loss
 recorded in 2024.
General

9. We note your disclosure on the cover page that "[n]o securities are
registered as part
 of this statement." Please note General Instruction A to Form 10, which
states, "Form
 10 shall be used for registration pursuant to Section 12(b) or (g) of
the Securities
 Exchange Act of 1934 of classes of securities of issuers for which no
other form is
 prescribed." Please revise your registration statement to comply with
the requirements
 of Form 10, including disclosing the class of securities to be
registered. Additionally,
 please update your Description of Registrant's Securities To Be
Registered on page 18
 to include all relevant information as of the latest practicable date.
We note that your
 current disclosure appears to be as of December 31, 2024. Refer to Item
202 of
 Regulation S-K.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact Suying Li at 202-551-3335 or Angela Lumley at
202-551-3398 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Reginald L. Sewell
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</DOCUMENT>

September 30, 2025
Reginald Fubara
Chief Executive Officer
HyOrc Corporation
050 Post Oak Boulevard, Suite 510-Q60
Houston, TX 77056
Re:HyOrc Corporation
Registration Statement on Form 10
Filed September 22, 2025
File No. 000-51048
Dear Reginald Fubara:
            Our initial review of your registration statement indicates that it fails in numerous
material respects to comply with the requirements of the Securities Exchange Act of 1934,
the rules and regulations thereunder and the requirements of the form.  More specifically,
•The financial statements are incomplete as no interim financial statements have been
included. Refer to Item 13 of Form 10 and Item 8-08 of Regulation S-X.
            This registration statement will become effective automatically 60 calendar days after
the filing date . If the registration statement were to become effective in its present form, we
would be required to consider what recommendation, if any, we should make to the
Commission. We suggest that you consider filing a substantive amendment correcting the
deficiencies or a request for withdrawal of the registration statement before it becomes
effective. We will provide more detailed comments relating to your registration statement
following our review of a substantive amendment that addresses these deficiencies.
            Please contact Alyssa Wall at 202-551-8106 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Reginald L. Sewell

March 31 , 2015

Via E -mail
Fan Haoran
Chief Executive Officer
Asia Properties , Inc.
119 Commercial St., Suite 190 -115
Bellingham, WA 98225

Re: Asia Properties , Inc.
 Current Report on Form 8-K
Filed January 20 , 2014
File No. 000-51048

Dear Mr. Haoran :

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission  from taking
any action with respect to the company or the filing and 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.  We urge all pe rsons who are responsible for the
accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Tom Kluck

Tom Kluck
Branch Chief

January  29, 2015

Via E -mail
Fan Haoran
Chief Executive Officer
Asia Properties , Inc.
119 Commercial St., Suite 190 -115
Bellingham, WA 98225

Re: Asia Properties , Inc.
 Current Report on Form 8-K
Filed January 20 , 201 5
File No. 000-51048

Dear Mr. Haoran :

Our preliminary review of your filing indicates that it fails in numerous material respects to
comply with the requirements of the Securities Exchange Act of 1934, the rules and regulations
under that Act, and the require ments of the form.   Please respond to this letter within ten business
days by amending your filing, by providing the requested information, or by advising us when
you will provide the requeste d response.   If you do not believe our comment applies 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 you provide in
response to this comment , we may have  additional comments.

General

1. We note from the disclosure in the above -referenced Form 8 -K that you issued
950,000,000 shares of your common stock to shareholders of Asia Innovation
Technology Limited in ex change for the rights, titles and interests in the business assets
and all attendant or related assets of Asia Innovation Technology Limited.  Please amend
the Form 8 -K to provide the disclosure required by Item 1.01 and 2.01(f) of Form 8 -K
with respect to  the transaction .  Please also note that Item 9.01(c ) of Form 8 -K states that
the financial statements and pro forma financial information required under the item must
be filed in the initial report if the registrant was a shell company prior to the transaction
being disclosed in answer to Item 2.01 of Form  8-K.

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 information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are

Fan Haoran
Asia Properties, Inc.
January 29, 2015
Page 2

 in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

 In responding to our comment, 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;

 staff comments or changes t o disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 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.

Please contact Kim McManus , Staff Attorney, at (202) 551 -3215 or Jennifer Gowetski  at
(202) 551 -3401  with any other questions.

Sincerely,

 /s/ Jennifer Gowetski

Jennifer Gowetski
Special Counsel