May 2, 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. 4 Filed April 10, 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.

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:

* Mr. Field, your sole officer and director, maintains a personal
relationship with each shareholder and the dates of the issuances
were between May 16, 2005 and June 18, 2005,
* 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 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.
Accordingly, please revise to include a fixed price and to
identify
the selling shareholders as underwriters.

*	*	*

      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.

      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.
May 2, 2006
Page 2