SecProbe.io

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							April 15, 2005

via facsimile and U.S. mail

Mr. Russell L. Smith
Chief Executive Officer
Vision Energy Group, Inc.
4333 Admiralty Way, Suite 100P
Marina del Ray, CA 90291

	Re:	Vision Energy Group, Inc. (formerly O`Hara Resources,
Ltd.)
		Form 10-QSB, Filed March 31, 2005
		Form 10-KSB/A, Filed April 6, 2005
		Form 10-QSB/A, Filed April 6, 2005
		Response letter, Filed April 11, 2005
		File No. 000-16602

Dear Mr. Smith:

      We have reviewed the above filings and response letter and
have
the following comments.  Our review has been limited to the areas
commented on below.  Where indicated, we think you should revise
your
documents 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 or may not
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
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

10-QSB for the quarter ended January 31, 2005

Controls and procedures, page 11

1. We note that your certifying officer discloses his conclusion
as
to the effectiveness of your disclosure controls and procedures
"...within 90 days of the filing date of this quarterly report."
However, Item 307 of Regulation S-B requires that your certifying
officers disclose their conclusions regarding the effectiveness of
your disclosure controls and procedures as of the end of the
period
covered by the report.  As explained in prior comment 6, you
should
refer to Item 601(b)(31) of Regulation S-B for the specific
language
required in the certifications.  The guidance in paragraph 4(c)
concerns the appropriate timing of the required evaluation.

2. Item 307 of Regulation S-B requires you to disclose the
conclusions of your principal executive and principal financial
officers, or persons performing similar functions, regarding the
effectiveness of your disclosure controls and procedures as of the
end of the period covered by the report.  Based on this guidance,
the
wording you have included is not sufficient.

3. You also state that there were no "significant changes" in your
internal controls and no factors that could "significantly affect"
these controls subsequent to the date of your evaluation.
However,
Item 308(c) of Regulation S-B requires that you disclose any
change
in your "internal control over financial reporting" identified in
connection with the evaluation required by paragraph (d) of
Exchange
Act Rules 13a-15 or 15d-15 that occurred during the fourth fiscal
quarter that has materially affected, or is reasonably likely to
materially affect, your internal controls over financial
reporting.
The representations required are specified in Regulation S-B, Item
601(b)(31), paragraph 4(d).

Exhibit 31.1

4. The wording of your certification does not comply with that
required under Section 302, paragraph 4(c), of the Sarbanes-Oxley
Act
of 2002.

10-KSB/A for the year ended April 30, 2004

Controls and Procedures, page 20

5. The disclosures you provided under this heading are not
sufficient.  Please refer to comments 1, 2 and 3 above for
guidance.

Exhibit 31.1

6. Please note that every amendment to a periodic report must
include
updated certifications required by Item 601(b)(31) of Regulation
S-B.
The required certification must, at the very least, and only under
certain conditions, include paragraphs 1 and 2.  If the amendment
to
the periodic report does not involve any changes to the financial
statements or other financial information, paragraph 3 may be
omitted.  If the amendment to the periodic report does not amend
the
Item 307 and 308 disclosures, then paragraphs 4 and 5 may be
omitted.
Please confirm that you understand and will comply with these
updating requirements when filing your amendments.

10-QSB/A for the quarter ended October 31, 2004

7. Your disclosures regarding Controls and Procedures on page 8,
and
your Exhibit 31.1 Certification, are non-compliant.  Please follow
the guidance in the comments above.

Closing Comments

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please understand that we may have additional comments after
reviewing your responses to our comments.

      You may contact Jennifer Goeken at (202) 824-5287 or Karl
Hiller at (202) 942-1981 if you have questions regarding comments
on
the financial statements and related matters.  Please contact me
at
(202) 942-1870 with any other questions.  Direct all
correspondence
to the following ZIP code:  20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director

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Vision Energy Group Inc. (FKA O'Hara Resources, Ltd.)
April 15, 2005
page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

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