October 5, 2007


Via Edgar and Federal Express


United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington D.C. 20549-7010
Attn:    John Cash
         Accounting Branch Chief

Re:      Greenshift Corporation
         Form 10-KSB for the Fiscal Year Ended December 31, 2006
         File No. 0-28887

Dear Mr. Cash:

Based upon the Staff's review of the filing noted above, the Commission issued a
comment  letter dated October 2, 2007.  The following  consists of the Company's
response to the Staff's comment  letter.  For the convenience of the Commission,
the  comment  is  repeated  verbatim  with the  Company's  response  immediately
following.

FORM 10-QSB FOR THE PERIOD ENDED JUNE 30, 2007

Statement of Cash Flows, page 7

1.   Comment:  We note your  response to prior  comment 5 and your  reference to
     Regulation  S-X. As a small business  issuer you should refer to Regulation
     S-B. Item  310(b)(1)  (iii) of Regulation S-B does not provide for the same
     level of  condensing  afforded  under  Article 10 that you have quoted.  We
     continue to believe  that  additional  disclosure  regarding  your  interim
     period  operating  cash flows would be material to your  investors.  Please
     revise  your  future  interim  filings to provide a  reconciliation  of net
     income (loss) to net cash provided by (used in)  operating  activities,  or
     alternatively disclose this underlying information in the footnotes to your
     financial statements.






Mr. John Cash
October 5, 2007
Page 2


          Response:  We respectfully  note your comment and will ensure that our
          future filings  include a  reconciliation  of net income (loss) to net
          cash  provided by (used in)  operating  activities in our Statement of
          Cash Flows.

We are in the process of  completing  our amended  December 31, 2006 Form 10-KSB
and our amended March 31, 2007 Form 10-QSB and originally  planned to filed such
amendments  on  October  5,  2007.  In light of the  comment  above we will need
additional  time to  incorporate  the change in our March 31, 2007  Statement of
Cash Flows. We anticipate filing all amended filings by October 12, 2007.



                                   Sincerely,

                                   /s/ Jacqueline Flynn
                                   ------------------------------------
                                       Jacqueline Flynn
                                       Chief Financial Officer