Mark C Lee
Tel 916.442.1111
Fax 916.448.1709
leema@gtlaw.com


May 1, 2014

VIA EDGAR AND FEDERAL EXPRESS

Justin Dobbie
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C.  20549

Re: Stevia Corp.
    Registration Statement on Form S-1
    Filed April 8, 2014
    File No. 333-195123

Dear Mr. Dobbie:

     On behalf of Stevia Corp., a corporation organized under the laws of Nevada
(the  "COMPANY"),  we are responding to the comment in the letter from the Staff
dated April 29, 2014  relating to the Company's  Registration  Statement on Form
S-1 filed on April 8, 2014. The responses below have been numbered to correspond
with the comments in your April 29, 2014 letter.

GENERAL

     1.   IT APPEARS THAT YOU ARE REGISTERING  SHARES  UNDERLYING THE ADDITIONAL
          CONVERTIBLE  NOTE  DESCRIBED ON PAGE 4. IT ALSO APPEARS THAT YOU REFER
          TO THIS AS THE "SECONDARY  NOMIS BAY NOTE" IN FOOTNOTES 4 AND 5 TO THE
          CALCULATION OF REGISTRATION  FEE TABLE ON THE  REGISTRATION  STATEMENT
          COVER PAGE.  WE NOTE FROM THE  REGISTRATION  STATEMENT  COVER PAGE AND
          FROM PAGE 4 THAT YOU HAVE NOT YET ISSUED THIS NOTE.  PLEASE PROVIDE US
          YOUR LEGAL ANALYSIS EXPLAINING WHY YOU ARE ABLE TO REGISTER THE RESALE
          OF SHARES  UNDERLYING THE ADDITIONAL  CONVERTIBLE  NOTE GIVEN THAT YOU
          HAVE NOT YET  ISSUED  THAT  NOTE.  REFER TO  SECURITIES  ACT  SECTIONS
          COMPLIANCE & DISCLOSURE INTERPRETATION 134.01 FOR GUIDANCE.

Company Response to Comment 1:

     We are respectfully responding to the Staff's comment as follows:  Question
139.11  of  the  Compliance  and  Disclosure  Interpretations:   Securities  Act
Sections,  dated May 16, 2013 (the  "C&DIs")  provides,  in pertinent  part,  as
follows:

     "In a PIPE transaction,  a company will be permitted to register the resale
of  securities  prior to their  issuance if the company has  completed a Section
4(2)-exempt sale of the securities (or in the case of convertible securities, of

Securities and Exchange Commission
Division of Corporate Finance
May 1, 2014
Page 2



the convertible security itself) to the investor,  and the investor is at market
risk at the time of filing of the resale  registration  statement.  The investor
must be  irrevocably  bound to  purchase  a set number of  securities  for a set
purchase price that is not based on market price or a fluctuating ratio,  either
at the time of  effectiveness  of the resale  registration  statement  or at any
subsequent date. WHEN A COMPANY ATTEMPTS TO REGISTER FOR RESALE SHARES OF COMMON
STOCK UNDERLYING UNISSUED,  CONVERTIBLE SECURITIES, THE PIPE ANALYSIS APPLIES TO
THE CONVERTIBLE  SECURITY,  NOT TO THE UNDERLYING COMMON STOCK.  There can be no
conditions to closing that are within an investor's  control or that an investor
can cause not to be  satisfied.  For  example,  closing  conditions  in  capital
formation  transactions relating to the market price of the company's securities
or the  investor's  satisfactory  completion of its due diligence on the company
are  unacceptable  conditions.  The  closing  of the  private  placement  of the
unissued  securities must occur within a short time after the  effectiveness  of
the resale registration statement. [Nov. 26, 2008]" (emphasis added)

     We respectfully submit that the transactions contemplated by the Securities
Purchase Agreement,  dated as of March 3, 2014 (the "Purchase  Agreement"),  and
the related transaction documents fully comply with the above Staff guidance.

     The transactions  contemplated by the Purchase  Agreement were completed as
of March 3, 2014, because the investor was at market risk as of that date, which
preceded the April 8, 2014 date of filing of the Company's  resale  registration
statement on Form S-1 (the  "Registration  Statement")  with the  Securities and
Exchange  Commission (the  "Commission").  As of March 3, 2014,  pursuant to the
Purchase Agreement,  the investor had completed the purchase of the Initial Note
(as defined in the Purchase  Agreement)  for a fixed  purchase price of $340,000
and was  irrevocably  bound to purchase the  Additional  Note (as defined in the
Purchase  Agreement)  for a fixed  purchase  price of  $600,000,  subject to the
satisfaction  of  the  conditions  in the  Purchase  Agreement  relating  to the
Additional Closing Date (as defined in the Purchase  Agreement).  Regarding such
conditions,  in accordance with the above-referenced  guidance,  we respectfully
note that there are no  conditions  in the  Purchase  Agreement  relating to the
Additional  Closing  Date that are  within  the  investor's  control or that the
investor  can  cause not to be  satisfied.  Moreover,  there  are no  conditions
relating  to the market  price of the  company's  securities  or the  investor's
satisfactory  completion  of its due diligence on the company.  Accordingly,  in
accordance  with the  above-referenced  guidance,  the investor was  irrevocably
bound to purchase a set number of  securities  (i.e.,  one Initial  Note and one
Additional  Note) for a set purchase price (i.e.,  $340,000 for the Initial Note
and  $600,000  for the  Additional  Note) that is not based on market price or a
fluctuating  ratio,  either  at the time of  effectiveness  of the  Registration
Statement or at any  subsequent  date.  As a result,  the investor was at market
risk as of March 3, 2014,  the date the Purchase  Agreement was executed,  which
was well in  advance  of the April 8,  2014  date of filing of the  Registration
Statement with the Commission.

Securities and Exchange Commission
Division of Corporate Finance
May 1, 2014
Page 3



     We  respectfully  note that, as expressly  stated in the above  highlighted
portion  of  Question  139.11  the  C&DIs,  this PIPE  analysis  APPLIES  TO THE
CONVERTIBLE SECURITIES (i.e., the Initial Note and the Additional Note), AND NOT
TO THE  UNDERLYING  COMMON  STOCK.  Accordingly,  it is not relevant to the PIPE
analysis  that the  Initial  Note and the  Additional  Note are  convertible  at
variable conversion prices and that the number of shares of the Company's common
stock issuable upon conversion  thereof is not fixed.  What matters is only that
the investor be irrevocably bound to purchase a fixed number of NOTES at a fixed
price that is not based on market price or fluctuating  ratio.  This requirement
is clearly  satisfied  under the terms of the  Purchase  Agreement,  because the
investor  purchased  the  Initial  Note at a fixed price of $340,000 on March 3,
2014 and is irrevocably  bound to purchase the Additional  Note at a fixed price
of $600,000 on the Additional  Closing Date,  provided all the conditions to the
Additional  Closing  Date are  satisfied,  including  the  effectiveness  of the
Registration Statement.

     Moreover,  since the Additional Closing Date would occur on or prior to the
10th  trading  day  after  effectiveness,   we  respectfully  believe  that  the
requirement, as stated in the above-referenced guidance, that the closing of the
private placement of the unissued securities occur within a short time after the
effectiveness of the Registration Statement is also satisfied under the terms of
the Purchase Agreement.

     For  all  of  the  foregoing  reasons,  we  respectfully  submit  that  the
transactions  contemplated by the Purchase Agreement and the related transaction
documents fully comply with the above-referenced  Staff guidance and, therefore,
the offering of the shares of the Company's  common stock underlying the Initial
Note and the Additional  Note is a valid secondary  offering,  and should not be
treated as an indirect primary offering.

     Finally,  we respectfully refer the Staff to the Registration  Statement on
Form S-1 (File No.  333-193103) of Armco Metals  Holdings,  Inc., filed with the
Securities and Exchange  Commission (the  "Commission") on December 27, 2013 and
declared effective on February 14, 2014 (the "Armco Metals S-1"). Similar to the
Registration  Statement,  the Armco Metals S-1 registered the offering of common
stock  underlying both an issued  convertible  note and an unissued  convertible
note in connection with a transaction that was structured virtually  identically
to the transaction  contemplated by the Purchase  Agreement.  The Staff issued a
comment  letter  dated  January 23, 2014 in respect of the Armco Metals S-1 (the
"Armco  Comment  Letter").  Comment No. 2 in the Armco  Comment  Letter sought a
legal analysis  similar to the analysis  sought here by the Staff  regarding the
basis for the  characterization  of the resale  offering of the  securities as a
valid secondary offering given that the Additional Note has not yet been issued.
By letter dated January 28, 2014,  Armco  responded to the Staff's Comment No. 2
in the Armco Comment Letter with the same analysis set forth above. As a result,
the Armco Metals S-1 was declared effective on February 14, 2014.

Securities and Exchange Commission
Division of Corporate Finance
May 1, 2014
Page 4



SELLING SECURITY HOLDERS, PAGE 15

     2.   PLEASE  TELL  US  WHETHER  ANY OF THE  SELLING  SECURITY  HOLDERS  ARE
          BROKER-DEALERS.  TO THE  EXTENT  THAT  ANY  SELLING  SHAREHOLDERS  ARE
          BROKER-DEALERS  PLEASE  REVISE  TO NAME  THEM AS  UNDERWRITERS  IN THE
          PROSPECTUS.

Company Response to Comment 2:

     The  Company  respectfully  informs  the  Staff,  that none of the  selling
security  holders are  broker-dealers,  nor are they  affiliates  or  associated
persons of a registered broker-dealer.

                                       ***

     We hope that the foregoing  addresses all of the Staff's comments contained
in its  letter  dated  April 29,  2014.  In the  event the Staff has no  further
comments, we would appreciate written correspondence to that effect.

     If you have any questions  regarding this response,  please do not hesitate
to contact me directly at (916) 442-1111.


Best regards,


/s/ Mark C Lee
-------------------------------
Mark C Lee
Shareholder
Enclosures

Securities and Exchange Commission
Division of Corporate Finance
May 1, 2014
Page 5



                                 ACKNOWLEDGEMENT

In connection with Stevia Corp.'s (the "COMPANY") letter dated May 1, 2014
addressed to the Securities Exchange Commission, we acknowledge the following:

     *    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.

Stevia Corp.


/s/ George Blankenbaker
-----------------------------------------------------
George Blankenbaker, President, Secretary & Treasurer