Strategic Global Investments, Inc. (STBV)

[janice shell]

STBV does not have a "partnership" with HEMP:

2. We note news releases dated June 12, 2014 and June 20, 2014 announcing agreements between Hemp, Inc. and the Company and TV 101 and the Company relating to the Company's media services. Please revise to discuss the material terms of these arrangements and file the underlying agreements as exhibits to the offering statement.

Response: The Company respectfully states that it did not issue either of the press releases referred to in the Comment, and has no responsibility for their content. As to Hemp, Inc., the Company has never had a contract with that company or even any contact with it. The Company had a consulting agreement with an affiliate of that company, but that agreement has been terminated by the Company for non-performance, and it has made no payments to the affiliate under the agreement. The Company does not believe that there is any disclosure to be made by the Company about the affiliate or Hemp, Inc.

http://www.sec.gov/Archives/edgar/data/823187/000000000014049733/filename1.pdf