SecProbe.io

October 9, 2014

Via E -mail
Robert G. Watson, Jr.
Chief Executive Officer
EnerJex Resources, Inc.
4040 Broadway, Suite 508
San Antonio, TX  78209

Re: EnerJex Resources, Inc.
  Registration Statement on Form S-1
Filed  September 25, 2014
  File No.  333-198949

Dear Mr. Watson :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

Registration Statement on Form S -1

General

1. Please revise your filing to provide the information about the interests of named experts
and counsel required by Item 509 of Regulation S -K with regard to Michael E. Pfau and
the Pfau Revocable Trust of 2003.

Index to Exhibits, page II -5

2. Please provide as Exhibit 5.1 the legality opinion required by Item 601(b)(5) of
Regulation S -K.

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 the information the Securities Act of 193 3 and

Robert G. Watson, Jr.
EnerJex Resources, Inc.
October 9, 2014
Page 2

 all applicable Securities  Act rules require.   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 you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
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 t o 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 effect iveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceler ation of the effective date of the registration statement as 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.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Norman von  Holtzendorff, Senior Counsel, at (202) 551 -3237  or me at
(202) 551 -3740  with any other questions.

Sincerely,

 /s/H. Roger Schwall

H. Roger Schwall
Assistant Director