[LETTERHEAD GOFF CORPORATION ]


                                November 10, 2011

VIA EDGAR

United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549

Re: Goff Corporation (the "Company")
    Registration Statement on Form S-1
    File No. 333-176509

Ladies and Gentlemen:

     In accordance with Rule 461 under the Securities Act of 1933, as amended,
the undersigned respectfully requests that the effective date for the
Registration Statement referred to above be accelerated so that it will be
declared effective at 4:00 PM on November 10, 2011, or as soon thereafter as is
practicable.

     The Company hereby acknowledges 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 staff comments and the declaration of
          effectiveness as a defence in any proceeding initiated by the
          Commission or any person under the federal securities laws of the
          United States.

                                Very truly yours,


                                By: /s/ Gary O'Flynn
                                   ---------------------------------
                                Name:  Gary O'Flynn
                                Title: President and CEO