October 25, 2006	Robert S. Warren 781.895.5922 rwarren@foleyhoag.com
Via EDGAR

Division of Corporation Finance

Securities and Exchange Commission

Washington, DC 20549

Attn:       Larry Spirgel, Assistant Director

Paul Fischer, Staff Attorney

Re:Global Matrechs, Inc. Registration Statement on Form SB-2

On behalf of Global Matrechs, Inc., we are hereby filing this Pre-Effective Amendment No. 1 to the Registration Statement on Form SB-2 (SEC file # 333- 137833) for the purpose of including Exhibit 5.1 in the Registration Statement.

We would like to take this opportunity to thank you again for your continued assistance with this matter. Please feel free to contact David Broadwin, Matt Eckert or me with any questions.

Regards,

/s/ Robert S. Warren

Robert S. Warren

RSW

Enclosure