Strategic Global Investments (STBV) CORRESP Correspondence with SEC

Strategic Global Investments, Inc.

701 Palomar Airport Road, Suite 300

Carlsbad, California 92011

September 14, 2015

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Mr. Larry Spirgel

Re: Strategic Global Investments, Inc.

Offering Statement on Form 1-A

Filed August 26, 2015

File No. 024-10470

Acceleration Request

Requested Date:      September 16, 2015

Requested Time:     3:00PM Eastern Time

Gentlemen:

Strategic Global Investments, Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to declare the above-captioned Offering Statement on Form 1-A qualified at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable.

The Company hereby authorizes Warren J. Archer, who is an attorney with the Company’s outside legal counsel, Morella & Associates, to orally modify or withdraw this request for acceleration.

The Company hereby acknowledges that:

• should the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the filing qualified, 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 qualified, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• the Company may not assert the staff comments and the declaration of qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The Company also agrees that it will only sell shares of its common stock pursuant to the subject Offering Statement in states where the offering is registered or where there is an applicable exemption from the applicable state’s securities law available.

The Company requests that it be notified of such qualification by a telephone call to Warren Archer at (412) 369-9696 or email to him at: wjarcher@morellalaw.com.

Very truly yours,

STRATEGIC GLOBAL INVESTMENTS, INC.

By:	/s/ Andrew T. Fellner
	Andrew T. Fellner
	President and Chief Executive Officer