SecProbe.io

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404
DIVISION OF
CORPORATION FINANCE
Mail Stop 05-07
        							December 28, 2004

Via U.S. Mail

David R. Robinson
President and Chief Executive Officer
Forum Energy
Suite 1400
700-2nd  Street
SW Calgary, AB.
T2P 4V5
Canada

RE:		Forum Energy
		Form 20-F for the year ended December 31, 2003
		File No.  0-17729

Dear Mr. Robinson:

      We have limited our review of your Form 20-F to disclosures
relating to your contacts with countries that have been identified
as state sponsors of terrorism, and will make no further review of
the Form 20-F.  Our review with respect to this issue does not
preclude further review by the Assistant Director group with respect to
other issues.  At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure.  Please be as detailed as necessary in your response.
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 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 20-F for the year ended December 31, 2003

General  -
We note the disclosure in Note 2 to the 2002 financial statements,
On p.59, that the Company had an Iranian subsidiary, Tracer Petroleum
Iran Limited; and the disclosure on p.16, and in Note 9 to the
2002 financial statements on p.65, regarding the Company`s development
activities in Iran.  It appears from Exhibit 9, a list of the
Company`s subsidiaries, that the Company no longer has an Iranian
subsidiary.  In light of the fact that Iran has been identified by
the U.S. State Department as a state sponsor of terrorism, and is
subject to economic sanctions administered by the U.S. Treasury
Department`s Office of Foreign Assets Control, please advise us of
the status of the Company`s Iranian subsidiary; and the
materiality to the Company of its prior and/or existing Iranian subsidiary and
its development activities in Iran.  Give us your view as to
whether the Company`s prior and/or existing operations and development
activities in Iran constitute a material investment risk for your
security holders.  In preparing your response, please consider
that evaluations of materiality should not be based solely on
quantitative factors, but should include consideration of all factors that a
reasonable investor would deem important in making an investment
decision.

Closing

      Please understand that we may have additional comments after
We review your response to our comment.  You may contact me at
(202)942-7817 if you have any questions about the comment or our review.

								Sincerely,

								Cecilia Blye, Chief
								Office of Global Security
								Risk

cc: 	Roger Schwall
	Assistant Director
	Division of Corporation Finance

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