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CORRESP
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   Filed by Automated Filing Services Inc. (604) 609-0244 - TransGlobe Energy Corporation - Corresp

     Suite 2500, 605 - 5th Avenue S.W.   Tel:
      (403) 264-9888   Email: trglobe@trans-globe.com

      Calgary, Alberta, Canada T2P 3H5   Fax: (403) 264-9898   Web:
      www.trans-globe.com

September 29, 2005

United States Securities and Exchange Commission
100 F
Street, NE
Washington,
DC 20549-7010
U.S.A.

Attn: Ms. Jennifer Goeken, Division of Corporation Finance

Dear Ms. Goeken:

    Re:
    TransGlobe Energy Corporation

    Form 40-F for Fiscal Year Ended December 31,
      2004

    Filed March 29, 2005

    File No. 001-31891

This letter sets forth the response of TransGlobe Energy
Corporation (the "Company" or “TransGlobe”) to the comments set forth in the
Staff’s letter dated September 16, 2005 in connection with the Company’s Annual
Report on Form 40-F for the year ended December 31, 2004, File No. 001-31891,
filed with the U.S. Securities and Exchange Commission on March 29, 2005 (the
"Annual Report"). For your convenience, we have set forth the comments in the
Staff’s letter followed by the Company’s response.

Form 40-F for the Fiscal Year Ended December 31,
2004

Consolidated Statement of Cash Flow

    1.

      We note you present a subtotal of Cash flow from
      operations in your reconciliation of net income to net cash provided by
      operating activities. We also note your disclosure under Selected Annual
      and Quarterly Information, where you indicate that this measure is non-
      GAAP and “represents cash generated from operating activities before
      changes in non-cash working capital.” Please support your presentation of
      this subtotal under Canadian GAAP as there does not appear to be a
      provision within CICA 1540 for this presentation. In this regard, note
      that the Illustrative example in CICA 1540 presents a subtotal that
      includes “items not affecting cash” before arriving at “Net cash provided
      by (used in) operating activities” that does not include net
      income.

      Response:

      CICA HB1540 does not specifically provide for the
      presentation of this subtotal in the cash flow from operating activities
      and it also does not specifically disallow the presentation of this
      subtotal. Therefore, the Company believes this presentation is not
      specifically addressed under Canadian GAAP.

2

      In response to the Staff’s comment, TransGlobe will not
      include this subtotal in the consolidated statement of cash flows nor in
      the Selected Annual and Quarterly Information in future filings.

General and Administrative Expenses

    2.

      We note that you have capitalized approximately 35% of
      gross G&A for the fiscal year ended December 31, 2004. Please confirm,
      for Canadian to US GAAP reconciliation purposes, that you have complied
      with Article 4-10(c)(2) of Regulation S-X, which stipulates that any
      internal costs that are capitalized shall be limited to those costs that
      can be directly identified with acquisition, exploration and development
      activities undertaken. We note your disclosure with your Property and
      Equipment accounting policy that capitalized costs include “overhead
      charges directly related to acquisition, exploration and development
      activities.”

      Response:

      TransGlobe confirms that for US GAAP purposes we have
      complied with Article 4-10 (c)(2) of Regulation S-X. The significant
      increase over 2003 is a result of a new exploration project in
    Egypt.

TransGlobe acknowledges that:

  The Company is responsible for the adequacy and accuracy of the disclosure
  in the filing;

  Staff comments on changes to disclosure in response to Staff comments do
  not foreclose the commission from taking any action with respect to the
  filing; and

  The Company may not assert Staff comments as a defence in any proceeding
  initiated by the Commission or any person under the federal securities laws of
  the United States.

If you have any further questions or comments please contact
the writer at your convenience.

Yours very truly,

TRANSGLOBE ENERGY CORPORATION

/s/ David Ferguson

David C. Ferguson, C.A.
Vice President
Finance & CFO