Cassidy & Associates
                         Attorneys at Law
                      9454 Wilshire Boulevard
                  Beverly Hills, California 90212
                            ----------

                    Email:  CassidyLaw@aol.com

Telephone: 202/387-5400                   Fax:  949/673-4525


                         March 13, 2012

John Reynolds
Assistant Director
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

          Re:  Hardwood Acquisition Corporation
               Form 10-12G
               File No. 000-54591

Dear Mr. Reynolds:

     In response to the Securities and Exchange Commission's letter
of February 23, 2012:

General

     1.   We note the statement on page F-8 that Tiber Creek will pay
	  all expenses incurred by you until consummation of a business
          combination.  It is unclear what agreement covers this and
          other relationships between you and Tiber Creek.  With a view
          to clarifying disclosure in the Form 10 and under Item
          601(b)(10) of Regulation S-K, advise us of any agreements
          between you and Tiber Creek.

     There is no written agreement between Tiber Creek Corporation and
Hardwood Acquistion Corporation (the "Registrant").  As disclosed in the
Form 10, Tiber Creek is owned by James Cassidy and James Cassidy is also
one of the two shareholders and directors of the Registrant.  Through
Mr. Cassidy, there is an unwritten understanding that Tiber Creek will
fund the expenses of the Registrant until the consummation of a business
combination.  Because of the nature of the Registrant and its absence
of any on-going operations, these expenses are anticipated to be
relatively low.

     2.   We note the statement on page 26 and elsewhere that resales of
          your shares "may be subject to the holding period and other
          requirements of Rule 144".  With a view to clarifying
          disclosure, please advise us fo your understanding regarding
          the applicability of Rule 144(i) under the Securities Act of
          1933,including the holding period and other restrictions in the
          context of your filing and planned business combination.

     It is our understanding of Rule 144 that if a company has ever been a
company with "no or nominal assets" or "assets consisting solely of cash
and cash equivalents" (a "shell" company") then the safe harbor provisions
of Rule 144 are not available until one year after the issuer has filed
current Form 10 information and has ceased to be a shell company, is
subject to the reporting requirements of section 13 or 15(d) of the Exchange
Act, and has filed all reports and other materials required to be filed by
section 13 or 15(d) of the Exchange Act, as applicable, during the preceding
12 months.


                         Sincerely,


                         Lee W. Cassidy