UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
      November 23, 2005

Mr. Allan J. Kent
Executive Vice President
Geoglobal Resources, Inc.
630 - 4th Avenue, SW - Suite 200
Calgary, Alberta T2P 0J9

      Re:	Geoglobal Resources, Inc.
		Registration Statement on Form S-3
      Filed October 25, 2005
		File No. 333-129225

Dear Mr. Kent:

      We have limited our review of your filing to those issues we
have addressed in our 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 information so we may better understand
your
disclosure.  After reviewing this information, we may 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. We note that you are registering for resale 2,223,772 shares of
your common stock "that are issuable on exercise of common stock
purchase warrants that are outstanding and that are issuable on
exercise of [ ] outstanding compensation options."  Your
disclosure
suggests that the purchase warrants are outstanding; however, it
appears they are issuable only on exercise of outstanding options.
Please advise.  Note that if the purchase warrants are not yet
outstanding, you may not register for resale the shares of common
stock issuable on exercise of such warrants.  Refer to Rule
415(a)(1)(iii) of the Securities Act of 1933.

2. Please revise the legality opinion to address the validity of
the
shares issuable upon the exercise of the outstanding compensation
options.

3. Your disclosure in the fee table regarding the shares issuable
on
the exercise of common stock purchase warrants issuable on the
exercise of compensation options appears to be inconsistent with
your
disclosure on page 3.  Please advise or revise.

Selling Securityholders, page 21

4. Expand the Selling Securityholders table to include the natural
persons with power to vote or to dispose of the securities offered
for resale by the entities that are listed as selling
securityholders.  If more than one holder is listed as beneficial
owner for the same securities, include explanatory text or
footnotes.
See Interpretation 4S of the Regulation S-K portion of the March
1999
supplement to the CF telephone interpretation manual.

5. Identify as underwriters all selling securityholders who are
registered broker-dealers, unless any such registered broker-
dealers
received the shares as compensation for investment banking
services.
Identify as underwriters all affiliates of registered broker-
dealers
that are listed as selling securityholders unless you can confirm
to
us that each (1) purchased its securities in the ordinary course
of
business and (2) at the time of purchase, had no agreements or
understandings, directly or indirectly, with any party to
distribute
the securities.  Refer to Item 507 of Regulation S-K.

6. Revise the Selling Securityholders table to include a column
that
indicates the percentage of the class (if one percent or more) to
be
owned by each securityholder upon completion of the offering.


Plan of Distribution, page 23

7. We note that the selling securityholders may engage in short
sales
of your common stock.  Please see Corporation Finance Telephone
Interpretation A.65 in that regard.

Closing Comments

      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 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 filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment 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 staff comments and the declaration
of
effectiveness 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.

      If you have any questions, please contact Carmen Moncada-
Terry
at (202) 551-3687 or, in her absence, the undersigned at (202)
551-
3685.

      	Sincerely,


      					Tangela Richter
      Branch Chief


cc: 	W. Clarke
      C. Moncada-Terry
Mr. Allan J. Kent
Geoglobal Resources, Inc.
November 23, 2005
Page 2