SecProbe.io

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      September 8, 2005

via U.S. Mail
Kathleen L. Quirk
Senior Vice President and Treasurer
McMoRan Exploration Co.
1615 Poydras Street
New Orleans, Louisiana 70112

      Re:	McMoRan Exploration Co.
Post Effective Amendment No. 1 to Registration Statement on Form
S-3
      	Filed August 10, 2005
      	File No. 333-121779

Dear Ms. Quirk:

      We have limited our review of the above filing to those
issues
that 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 supplemental 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.

Form S-3

Selling Securityholders, page 45
1. The disclosure you provide in footnote (d) at page 46 is
unclear.
Revise to identify clearly all selling securityholders who are
underwriters.
In that regard, identify all selling securityholders that are
registered broker-dealers or affiliates of registered broker-
dealers.
As for registered broker-dealers, indicate that such selling
stockholders are underwriters, unless such selling stockholder
received its securities as compensation for investment banking
services.  Similarly, with respect to any affiliate of a
registered
broker-dealer, please disclose, if true, that such selling
stockholder acquired its shares in the ordinary course of business
and at the time of the acquisition did not have any arrangements
or
understandings with any person to distribute the securities.  If
not,
you must indicate that such stockholder is an underwriter.

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 response to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

	Before the amended registration statement is declared
effective
pursuant to Section 8 of the Securities Act, the company should
provide us with a letter, 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 this action 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.

	Please contact Mellissa Campbell Duru at (202) 551-3757 with
any
questions, or in her absence, you may contact Timothy Levenberg,
Special Counsel, at (202) 551-3707.

      Sincerely,

							H. Roger Schwall
							Assistant Director
cc: 	via facsimile
	Douglas Currault II, Esq.
	Jones, Walker, Waechter, Poitevent, Carriere & Denegre, L.L.P
	225-248-2010 (fax)

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Ms. Quirk
McMoran Exploration Co.
September 8, 2005
page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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