EQUITABLE MINERAL & DEVELOPMENT INC
4440 S. PIEDRAS DR, SUITE 136
SAN ANTONIO, TX 78228
Telephone (210) 585-1813
Fax (210) 791-8292
July 16, 2020
The United States Securities and Exchange Commission
100 F. Street, N.E.
Washington, DC 20549
Attn:Kevin Dougherty
Laura Nicolson
Wei Lu or Ethan Horowitz
Loan Lauren Nguyen
Re:Equitable Mineral & Development Inc.
Registration Statement on Form S-1
File No. 333-237976
REQUEST FOR ACCELERATION OF EFFECTIVENESS
Ladies / Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Equitable Mineral & Development Inc. (the "Registrant" or the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-237796), as amended (the “Registration Statement”), so that it may become effective at 12:00 p.m. Eastern Daylight Time on July 22 2020, or as soon as practicable thereafter.
•Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing.
•The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing.
•The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Yours truly,
Equitable Mineral & Development Inc.
/s/ Timothy Austen Gard
Timothy Austen Gard
President
cc:Franklin Ogele, Esq.
