SecProbe.io

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							May 17, 2005

via facsimile and U.S. mail

Mr. James D. Eger
Chief Financial Officer
Continental Energy Corporation
14001 Dallas Parkway, Suite 1200
Dallas, Texas  75240

	Re:	Continental Energy Corporation
		Form 20-F, Filed January 26, 2005
		File No. 0-17863
      Response letter dated April 25, 2005
      Response letter dated May 9, 2005

Dear Mr. Eger:

      We have reviewed the above filing and response letters and
have
the following accounting comment.  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 our comment, 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 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.

20-F for the year ended July 31, 2004

Consolidated Schedule of Resource Property Costs

1. We note from your response to prior comment 4 that the amounts
presented in the line item "costs recovery" represent costs
recovered
from your joint venture partners under the Bengara-II and Yapen
Production Sharing Contracts.  We understand that under the
agreements, the partners are required to pay their share of
incurred
costs such that the interests in the properties be retained.  It
appears from your response that the agreements are not reflective
of
a typical production sharing contract whereby you do not receive
reimbursement for the partners` share of the costs but rather
recoup
the costs from future production.  As such, please consider
replacing
the line item "costs recovery" with a term that is not commonly
used
in industry to describe a fundamental feature of typical
production
sharing contracts.  Also, please expand on your discussion of
resource property costs to discuss the details provided in your
response regarding the Bengara-II and Yapen Production Sharing
Contracts such that it is clear what the reductions to the
resource
property costs represent.

Closing Comments

      As appropriate, please amend your filing and respond to this
comment 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
your amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your response to our comment and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
response
to our comment.

      You may contact Regina Balderas, Staff Accountant, at (202)
942-7768 or, in her absence, Jill Davis, Branch Chief, at (202)
942-
1996 if you have questions regarding comments on the financial
statements and related matters.  Direct questions relating to the
engineering issues to Ronald Winfrey, Engineer, at (202) 942-1778.
Direct questions relating to all other disclosure issues to the
undersigned at (202) 942-1870.  Direct all correspondence to the
following ZIP code:  20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director

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Continental Energy Corporation
May 17, 2005
page 1

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

         DIVISION OF
CORPORATION FINANCE

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