SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE
   Mail Stop 7010

         July 13, 2007

By US Mail and Facsimile

Mr. Steve Cochennet
President
Enerjex Resources, Inc.
7300 W. 110th, 7th Floor
Overland Park, KS  66210

Re: Enerjex Resources, Inc.
Registration Statement on Form SB-2
 Filed June 26, 2007
 File No. 333-144036

Dear Mr. Cochennet:

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 w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, 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 re view 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 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 and your CFO have “mutually terminated” his employment.  Supplementally, please tell us the reasons for his termination.

Mr. Steve Cochennet
Enerjex Resources, Inc.
July 13, 2007 Page 2
Signature Page
2. The Form SB-2 must be signed by both your principal financial officer, and
controller or principal accounting officer .  In your next amendment, please have
the persons acting in those capacities  sign the registration statement.

Exhibit 5.1
3. Please obtain and file as an exhibit a revised legal opinion.  The one you have filed is addressed to your Board of Director s and is limited to their use.  We refer
you to the first sentence of the penultimate  paragraph of the opinion.  Purchasers
of the securities must also be able to rely on the opinion.

 Closing Comments

As appropriate, please amend your regist ration 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 cove r 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 amendmen t and responses to our comments.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain th at the filing includes all information required
under the Securities Act of 1933 and that they have provide d 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 re quests 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 comment s and the declaration of effectiveness
as a defense in any proceeding initiat ed by the Commission or any person under
the federal securities laws of the United States.

Mr. Steve Cochennet
Enerjex Resources, Inc.
July 13, 2007 Page 3
 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision 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 conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te 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 acce leration of the effective date.

 We direct your attention to Rules 460 and 461 regarding requesting acceleration
of a registration statement.  Please allow ade quate 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 a dvance of the requested effective date.

  Please contact Donna Levy at (202) 551-3292 or, in her absence me, at (202)
551-3745 with any question.

Sincerely,

H. Roger Schwall
Assistant Director

cc: Anthony DeMent (via facsimile: 619-595-4883)
D. Levy