UNITED HERITAGE CORPORATION
Suite 200, One Energy Square, 4925 Greenville Avenue
Dallas, Texas 75206
April 23, 2008
Via EDGAR
Mr. H. Roger Schwall
Assistant Director
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | United Heritage Corporation | |
| | Form 10-KSB for the fiscal year ended March 31, 2007 | |
| | Filed July 16, 2007 | |
| | Form 10-QSB for the quarter ended June 30, 2007 | |
| | Filed August 20, 2007 | |
| | Form 10-QSB for the quarter ended September 30, 2007, as amended | |
| | Filed November 14, 2007 | |
| | Form 10-QSB for the quarter ended December 31, 2007, | |
| | Filed February 19, 2008 | |
| | Form 8-K filed December 4, 2007 | |
| | File No. 1-10179 | |
Dear Mr. Schwall:
United Heritage Corporation, a Utah corporation (“we”, “our” or the “Corporation”), is submitting this letter to you in conjunction with our filing of conformed copies of Amendment No. 1 to our annual report on Form 10-KSB for the fiscal year ended March 31, 2007, Amendment No. 1 to our quarterly report on Form 10-QSB for the quarter ended June 30, 2007, Amendment No. 1 to our quarterly report on Form 10-QSB for the quarter ended December 31, 2007, Amendment No. 2 to our Form 10-QSB for the quarter ended September 30, 2007 and Amendment No. 1 to our current report on Form 8-K filed on December 4, 2007 (collectively, the “Amendments”), in response to comments initially received from the staff (the “Staff”) of the Securities and Exchange Commission (“Commission”) on February 8, 2008.
We acknowledge that:
| · | we are responsible for the adequacy and accuracy of the disclosure in our filings; |
| · | Staff comments or changes to disclosure in response to Staff comments does not foreclose the Commission from taking any action with respect to our filing; and |
| · | we 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. |
Further, we undertake not to disclose estimates of oil and gas reserves other than proved or, in the case of other extractive reserves, estimates other than proved or probable reserves, and any estimated values of such reserves, in our press releases or filings with the Commission unless in accordance with the requirements Item 102 of Regulation S-K.
Should any member of the Staff have any questions or comments concerning, or desire any further information or clarification in respect of the Amendments, please do not hesitate to contact our counsel, Kevin Friedmann of Richardson & Patel LLP, at (212) 907-6688.
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UNITED HERITAGE CORPORATION |
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/s/ Joseph F. Langston, Jr. |
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| Chief Financial Officer |
