Mail Stop 6010

      November 7, 2005

David O`Neill
President
Global Electronic Recovery Corp.
6240 West 3rd Street, Suite 208
Los Angeles, CA 90036

      Re:	Global Electronic Recovery Corp.
	Amendment No. 1 to Registration Statement on Form SB-2
      Filed October 24, 2005
	File No. 333-127143

Dear Mr. O`Neill:

      We have reviewed your filing 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
information so we may better understand your disclosure.  After
reviewing this information, we may 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 comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Registration Statement on Form SB-2

Risk Factors, page 6
1. We reissue prior comment 3 with respect to the heading and body
of
Risk Factor 6 on page 8.  Please revise to clarify the closing
date
of the offering.

Use of Proceeds, page 11
2. Please reconcile your response to prior comment 15 and the
corresponding additional disclosure on page 12 with the following
disclosure appearing in the filing:
* "If we raise at least $100,000 we will pay Mr. O`Neill a
salary,"
pages 12 and 36;
* "If the maximum amount is raised, we intend to repay the amount
[Mr. O`Neill] loans us from the proceeds of this offering," page
35;
and
* "The director and officers will accept repayment of the loan
when
money is available," page 40.

Business, page 21
3. We reissue prior comment 27.  We have not received the cited
articles and industry reports.

Possible Solutions, page 28
4. We reissue prior comment 36.  Please provide us with a copy of
the
relevant Hewlett Packard statistics and tell us whether you have
obtained consent for their use.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 33
5. Please revise to provide detail concerning the items that
contributed to the loss you experienced from inception, in
addition
to your lack of revenues.

Officers and Directors, page 30
6. Please reconcile your statement in the second paragraph on page
34
that your "officers are unwilling to make any commitment to loan
[you] any money at this time" with your disclosure on page 35 that
Mr. O` Neill intends to loan you money as needed to pay
organizational and start-up costs and operating capital.

Exhibit 23
7. Please revise the filing to include an updated accountants`
consent.

*     *     *

      As appropriate, please amend your registration statement in
response to these comments.  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 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.

      You may contact Kevin Kuhar at (202) 551-3662 or Jay Webb at
(202) 551-3603 if you have questions regarding comments on the
financial statements and related matters.  Please contact Adelaja
Heyliger at (202) 551-3636 or me at (202) 551-3625 with any other
questions.

      Sincerely,



								Mary Beth Breslin
								Special Counsel


cc:  	Empire Stock Transfer
7251 West Lake Mead Blvd.
	Suite 300
	Las Vegas, NV 89128

David O`Neill
Global Electronic Recovery Corp.
November 7, 2005
Page 1