215 APolena Avenue
                        Newport Beach, California 92662
                              April 15, 2013

Securities and Exchange Commission
Division of Corporation Finance
Washington, DC 20549

                                    Re: Sandgate Acquisition Corporation
                                        Registration Statement on Form 10
                                        File No. 0-54830

To the Securities and Exchange Commission:

     Sandgate Acquisition Corporation (the "Company") has filed with the 
Securities and Exchange Commission (the "Commission") its registration 
statement on Form 10 (the "Registration Statement").  In regard to the 
Registration Statement, the Company and its management acknowledge that:

     The Company is responsible for the adequacy and accuracy of the
     disclosure in the filing;

     The comments of the Staff of the Securities and Exchange Commission
     or changes to the disclosure in response to such comments do not foreclose
     the Commission from taking any action with respect to the filing; and

     The Company may not assert Staff comments as a defense in any 
      proceeding initiated by the Commission or any person under the 
      federal securities laws of the United States.

                                SANDGATE ACQUISITION CORPORATION

                                By: James M. Cassidy