February 15, 2006

Mail Stop 4561

Russell Field
President, Director, Chief Executive Officer
Globepan Resources, Inc.
6518 121st Street, Suite 5
Surrey, British Columbia
Canada V3W 1C4

	Re:	Globepan Resources, Inc.
		Registration Statement on Form SB-2
      Amendment No. 3 Filed February 9, 2006
		Registration No. 333-128226

Dear Mr. Field:

	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
additional
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 comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

      The following comments refer to changes made in your
amendment
filed February 9, 2006.

General
1. As we stated in our prior comment 1 your offering appears to
constitute an offering by or on behalf of the registrant under
Rule
415(a)(4) since the registration statement covers the resale of
all
outstanding securities other than that held by Mr. Field, your
sole
officer, director, employee and 45% shareholder.   We note your
response to prior comment 1 that:

*  each shareholder warranted in the subscription agreement that
they
were acquiring the securities with investment intent and not a
view
to distribution,
*  Mr. Field, your sole officer and director, maintains a personal
relationship with each shareholder,
* you will receive no proceeds from the sale of securities, and
* the circumstance at the time of each issuance does not support
the
claim that a subsequent sale of securities was contemplated by the
selling stockholders.
 As we previously stated the issue of whether this is a primary
offering is a difficult factual one and not merely a question of
who
receives the proceeds.  Consideration should be given to how long
the
selling shareholders have held the shares, the circumstances under
which they received them, their relationship to the issuer, the
amount of shares involved, and whether under all the circumstances
it
appears that the sellers are acting as conduits for the issuer. In
this connection we note that the shares held by other than Mr.
Field
constitute all of your shares and appear to have been purchased at
significantly discounted prices only three months prior to the
time
this resale registration statement was filed.  Please expand to
explain further the relationship between Mr. Field and the selling
shareholders, including how they initially came into contact, and
clarify the circumstances surrounding the initial share purchases,
including the dates the shares were purchased.

Risk Factors
2. We note the reference to four mineral claims comprising the Nak
mineral claims held in trust by Ms. Kalris in your response to
previous comment 3.  Please revise to reconcile the reference to
only
two claims representing the Nak mineral claims on page 21.

*	*	*

      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 additional 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 filings 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.
	 Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	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; and

?	the company may not assert this action 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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact William Demarest at 202-551-3432 or Daniel
Gordon, Accounting Branch Chief, at 202-551-3486 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact Charito A. Mittelman at 202-551-3402 or
me
at 202-551-3495 with any other questions.

Sincerely,



Elaine Wolff
Branch Chief




Russell Field
Globepan Resources, Inc.
February 15, 2006
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