South Texas Oil Company (formerly known as Nutek Oil, Inc.) 6330 McLeod Drive, Suite 1 Las Vegas, NV 89120 Tel : (210) 568-9760 Fax : (210) 568-9761 May 17, 2005 To: Mr. H. Roger Schwall - Assistant Director Ms. Melinda Kramer Mr. Tangela Richter Securities Exchange Commission Division of Corporate Finance 450 Fifth Street, N.W., Mail Stop 04-05 Washington, D.C. 20549 RE: NUTEK OIL, INC. PRELIMINARY PROXY MATERIALS ON SCHEDULE 14C FILED MARCH 21, 2005 FILE NO. 0-50732 Dear Mr. Schwall, Here follows our responses to your comment letter dated April 14, 2005 which was received May 5, 2005. Preliminary Proxy Materials on Schedule 14C General 1. Expand your disclosure to explain how you obtained the 53.64% of the consents to effectuate the corporate actions disclosed in your preliminary Information Statement. We may have further comment. Disclosure in preliminary Information Statement has been expanded. 2. For each corporate action discussed in your preliminary Information Statement, provide the detailed disclosure required by Item 20 of Schedule 14A. Also, revise your list of proxy items for which you received consent to include the ratification of "all actions of the Company, its Officers and Directors since the last shareholders' meeting." The preliminary Information Statement has been revised to provide detailed disclosure as required by Item 20 of Schedule 14A. The list of proxy items has been revised by removing the wording, (received consent to include the ratification of "all actions of the Company, its Officers and Directors since the last shareholders' meeting.") Approve the performance based Stock Option Plan 3. Provide the information required by Item 10 of Regulation 14A. For example, you should briefly describe all material features of the plan, identify the class of persons to be eligible for the plan, indicate the approximate number of persons in each class, and state the basis of such participation. We may have further comment. The preliminary Information Statement has been revised to provide the information required by item 10 of Regulation 14A. If you have any questions or concerns regarding this comment letter or our filing, please do not hesitate to contact either one of the following individuals. Best regards, South Texas Oil Company /s/ Murray N. Conradie /s/ Jason F. Griffith, CPA Murray N. Conradie Jason F. Griffith, CPA President / CEO Chief Financial Officer 210-568-9760 (voice) 210-568-9760 (voice) 210-568-9761 (fax) 210-568-9761 (fax)