April 14, 2005


Via facsimile and U.S. Mail

Mr. Murray Conradie
President and Chief Executive Officer
Nutek Oil, Inc.
6330 McLeod Drive, Suite 1
Las Vegas, Nevada  89120

	Re:	Nutek Oil, Inc.
		Preliminary Proxy Materials on Schedule 14C filed March
31,
2005
		File No. 0-50732

Dear Mr. Conradie:

	We have reviewed your preliminary proxy materials and have
the
following comments.  Where indicated, we think you should revise
your
document in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. Expand your disclosure to explain how you obtained the 53.64%
of
the consents to effectuate the corporate actions disclosed in your
preliminary Information Statement.  We may have further comment.

2. For each corporate action discussed in your preliminary
Information Statement, provide the detailed disclosure required by
Item 20 of Schedule 14A.  Also, revise your list of proxy items
for
which you received consent to include the ratification of "all
actions of the Company, its Officers and Directors since the last
shareholders` meeting."

Approve the performance based Stock Option Plan

3. Provide the information required by Item 10 of Regulation 14A.
For example, you should briefly describe all material features of
the
plan, identify the class of persons to be eligible for the plan,
indicate the approximate number of persons in each class, and
state
the basis of such participation.  We may have further comment.

Closing Comments

      File revised proxy materials as necessary and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.


Please contact Melinda Kramer at (202) 942-1938 or, in her
absence,
Tangela Richter, Branch Chief, at (202) 942-1837, with any other
questions.  Address all correspondence to mail-stop 04-05.

								Sincerely,



								H. Roger Schwall
								Assistant Director

CC:	Melinda Kramer

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Nutek Oil
April 14, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE