SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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      November 2, 2005

Mr. Judson F. Hoover
Chief Financial Officer
Ness Energy International, Inc.
4201 East Interstate 20
Willow Park, Texas  76087

	Re:	Ness Energy International, Inc.
		Forms 10-KSB, 10-KSB/A1, 10-KSB/A2 and 10-KSB/A3
      for Fiscal Year Ended December 31, 2004
Filed March 31, 2005, April 8, 2005, April 18, 2005 and May 12,
2005
		Forms 10-QSB for Fiscal Quarters Ended
      March 31, 2005 and June 30, 2005
      Filed May 16, 2005 and August 19, 2005
      Response Letter Dated September 14, 2005
		File No. 0- 10301

Dear Mr. Hoover:

      We have reviewed your response letter and have the following
comments.  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 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 information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional
comments.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Critical Accounting Policies, page 18

1. We have reviewed your response to prior comment number three
and
are unable to locate your revised disclosure.  As previously
requested, please expand your disclosure to address SAB 106 with
respect to your accounting for asset retirement obligations
related to
assets that are accounted for under the full cost method.

Financial Statements

Consolidated Statements of Operations, page F-3

2. We have reviewed your response to prior comment number five. We
note the revisions you made to your presentation of other
comprehensive income.  Please further revise your presentation by
renaming the line item "Income before extraordinary item" to a
more
appropriate title such as "Net loss" or "Net loss before other
comprehensive loss".

Consolidated Statements of Cash Flows, page F-5

3. Please explain why you have classified asset retirement
obligations
as a component of your operating cash flows.

Note 2. Summary of Significant Accounting Policies, page F-6

Securities Issued for Property and Services

4. We have reviewed your response to prior comment number 7.
Please
compare and contrast your disclosure on page F-10 to that in your
critical accounting policy on page 6.  Additionally please support
your conclusion that it is appropriate to take into account
various
factors including, the number of shares, market, and other stock
restrictions when determining fair value.

Closing Comments

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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 amendment and responses to our comments.

	You may contact Regina Balderas, Staff Accountant, at (202)
551-
3722 or Jill Davis, Branch Chief, at (202) 551-3683 if you have
questions regarding comments on the financial statements and
related
matters.  You may contact James Murphy, Petroleum Engineer, at
(202)
551-3703 with questions about engineering comments.  Please
contact me
at (202) 551-3740 with any other questions.

								Sincerely,

								H. Roger Schwall
								Assistant Director

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Mr. Judson F. Hoover
Ness Energy International, Inc
November 2, 2005
page 1

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

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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