PARSONS/BURNETT/BJORDAHL/HUMELLP
_________________________________
ATTORNEYS
James B. Parsons
jparsons@pblaw.biz
VIA FACSIMILE (703-813-6982)
June 6, 2011
H. Roger Schwall
Assistant Director
US Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, DC 20549
Re:
Verde Resources, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed May 5, 2011
File No. 333-170935
Dear Mr. Schwall:
This letter is in response to your comment letter dated May 27, 2011, with regard to the Form S-1 filing of Verde Resources, Inc., a Nevada corporation (“Verde” or the "Company") filed on May 5, 2011. Responses to each comment have been keyed to your comment letter.
General
1.
All relevant updates have been made, including information pertaining to the May 17, 2011, payment.
2.
Information pertaining to the verbal agreement with the officers has been updated to more uniformly reflect the verbal agreement.
Suite 1850 Skyline Tower, 10900 NE 4th Street, Bellevue, WA 98004ŸT (425) 451-8036 ŸF (425) 451-8568Ÿwww.pblaw.biz
_________________________________________________________________
A Limited Liability Partnership with offices in Bellevue and Spokane
H. Roger Schwall
Division of Corporation Finance
Securities and Exchange Commission
June 6, 2011
Page2 of 2
Please contact this office with any further comments or questions. We are filing the redlined version and this letter on EDGAR correspondence. I would appreciate if you would send any further responses directly to me electronically or via facsimile, so I may assist Verde in a prompt response. If the SEC has no further comments, we expect to file a request for acceleration of the effective date.
Thank you in advance for your courtesies.
Very truly yours,
PARSONS/BURNETT/BJORDAHL/HUME, LLP
/s/ James B. Parsons
James B. Parsons
JBP:aqs
