| RE: | Virtual Sourcing, Inc. |
| Amendment No. 5 to Registration Statement on Form S-1 | |
Initial Form S-1 Filed: March 3, 2014 | |
File No. 333-194254 |
| · | the company providing your subsidiary Allied Recycling Corp (ARC) with barrels of Kruud Kleen, EYII LLC (EYII), was organized by the same individual, Norman Birmingham, as the company that you received your only purchase order from, FYA Field Services LLC (FYA); |
| · | EYII, FYA, and Gallant Acquisitions Corp. (which owns 20% of Allied Recycling Corp.) all have the same principal address listed in Rock Hill, South Carolina; |
| · | EYII and FYA were founded within two days of each other, on July 3, 2014 and July 1, 2014, respectively; and |
| · | Gallant Acquisitions Corp. is the registered agent for both EYII and FYA. |
| · | describe why Mr. Birmingham was willing to pay you a higher price for a barrel of Kruud Kleen than he sold it to you for; |
| · | Explain why EYII, FYA, and Gallant Acquisition Corp all have the same principal address; |
| · | disclose Mr. Birmingham’s current role at your company and detail his termination as CEO of Virtual Sourcing; |
| · | tell us whether there are any other registration statements of companies for which Mr. Birmingham has acted as a promoter or had a controlling interest; |
| · | detail how Exhibit 10.8 was reached only two days after EYII’s formation, including how EYII was able to provide such a large quantity of barrels in such a short period of time after formation; and |
| · | disclose that you have not actually sold any Kruud Kleen, nor do you have any current contractual arrangements to do so. |
| · | Mr. Birmingham has set up many companies in various states during his career, as a service provided to third party company owners. Mr. Birmingham does not own any equity in either EYII or FYA Field Services. Mr. Birmingham, as a favor to the individuals who own EYII and FYA, who were running a business as individuals with no corporate entity having been set up, set up the companies in order to give the owners of EYII and FYA some liability protection and a corporate structure. Mr. Birmingham does not own any equity of EYII or FYA, and is therefore not involved in the agreements between the Company, EYII and FYA. |
| · | Gallant Acquisitions Corp. is the resident agent for 9 companies in Wyoming, none of which it owns. Gallant Acquisitions acted as the initial resident agent for EYII and FYA in order to expedite the process of having EYII and FYA formed prior to the contracts being signed, so the contracts would not need to be signed directly with the individuals who own EYII and FYA. The address used was only for purposes of a registered office/agent address, and will be changed by the owners of EYII and FYA. |
| · | Mr. Birmingham was not terminated from Virtual Sourcing, Inc. He resigned from his positions with the company due to personal health reasons. As the only director of the company remaining in 2012, Mr. Birmingham immediately attempted to find a suitable board and officer group, and as soon as the officers and directors were selected, he resigned from all officer and director positions with the company. He currently assists with compliance work for the Company, but does not have a contract with the company and there are no plans to create a contract. |
| · | There are no other registration statements or companies for which Mr. Birmingham has acted as a promoter or had a controlling interest. |
| · | EYII and FYA were being run by individuals without any corporate entity being formed until July of 2014. The owners of EYII and FYA decided to form entities to run each of their respective businesses, in order to appear more professional and decrease personal liability. The businesses were operating prior to the formation of the actual corporate entities, they were not startup business, although they had not been run under a formal corporate entity. |
| · | The Company does have a contract to sell Kruud Kleen, and also has a purchase order for a minimum of 70 barrels of Kruud Kleen per week and a maximum of 105 barrels per week, which was included as Exhibit 10.9 to the previous submission. |
| · | Principal services and their markets, |
| · | Revenue Model and Distribution methods of the products or services, |
| · | Status of any publicly announced new product or service, |
| · | Sources and availability of raw materials and the names of principal suppliers, |
| · | Government and Industry Regulation, and |
| · | Government and Industry Regulation. |
