0001415889-12-001068.txt : 20120820 0001415889-12-001068.hdr.sgml : 20120818 20120718154729 ACCESSION NUMBER: 0001415889-12-001068 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120718 FILER: COMPANY DATA: COMPANY CONFORMED NAME: STW RESOURCES HOLDING CORP. CENTRAL INDEX KEY: 0001357838 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-CATALOG & MAIL-ORDER HOUSES [5961] IRS NUMBER: 000000000 STATE OF INCORPORATION: NV FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 619 WEST TEXAS AVENUE STREET 2: SUITE 126 CITY: MIDLAND, STATE: TX ZIP: 79701 BUSINESS PHONE: 432-686-7777 MAIL ADDRESS: STREET 1: 619 WEST TEXAS AVENUE STREET 2: SUITE 126 CITY: MIDLAND, STATE: TX ZIP: 79701 FORMER COMPANY: FORMER CONFORMED NAME: STW Global, Inc. DATE OF NAME CHANGE: 20100302 FORMER COMPANY: FORMER CONFORMED NAME: Woozyfly Inc. DATE OF NAME CHANGE: 20081006 FORMER COMPANY: FORMER CONFORMED NAME: PET EXPRESS SUPPLY INC DATE OF NAME CHANGE: 20060330 CORRESP 1 filename1.htm STW Resources Holding Corporation - FORM correspondence


STW RESOURCES HOLDING CORP.

619 West Texas Ave., Suite 126

Midland, Texas 79701


July 18, 2012


Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn:     Jennifer Thompson, Accounting Branch Chief

Sondra Snyder, Staff Accountant


Re:

STW Resources Holding Corp.

Form 8-K/A, Item 4.02

Filed July 10, 2012

File No. 000-52654


Ladies and Gentlemen:


The following response addresses the comment of the reviewing Staff of the Securities and Exchange Commission (Commission) as set forth in a comment letter dated July 13, 2012 (the "Comment Letter") relating to the Current Report on Form 8-K/A filed July 10, 2012 (the 8-K) of STW Resources Holding Corp. (the Company). The answer set forth herein refers to the Staffs comment by number.  

Item 4.02 Form 8-K, filed July 2, 2012

1.

Please note that you must respond in writing to the comments in our letter dated July 3, 2012 and in this letter. Merely filing an amendment to your Form 8-K is not an adequate response. Please submit your written response as correspondence on EDGAR as required by Rule 101 of Regulation S-T. As previously requested, in connection with responding to our comments, please provide, in writing, a 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 to 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.


Response

The Company acknowledges the Staffs comment and advises the Staff that the Company filed a response letter to the Staffs comment letter, dated July 3, 2012, on July 13, 2012 as correspondence on EDGAR as required by Rule 101 of Regulation S-T.  This response letter included the acknowledgement as set forth in the Staffs comment.


****

If you have any further comments and/or questions, please contact the undersigned at (432)528-4470 or Marc J. Ross, Esq. at Sichenzia Ross Friedman Ference LLP at (212) 930-9700.


Very truly yours,

/s/ Stanley Weiner

Stanley Weiner


cc:

Marc J. Ross, Sichenzia Ross Friedman Ference LLP