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[PETROQUEST ENERGY INC LETTERHEAD]

June 16, 2005

Via EDGAR and Federal Express

Mr. Karl Hiller

Branch Chief

United States Securities and Exchange Commission

Division of Corporate Finance

450 Fifth Street, N.W.

Washington, D.C. 20549-0405

    Re:

    PetroQuest Energy, Inc.

    Form 10-K for the fiscal year ended December 31, 2004

    Form 10-Q for the fiscal quarter ended March 31, 2005

    Response Letter dated May 3, 2005

    File No. 000-19020

Dear Mr. Hiller:

     This letter is in response to your letter dated June 6, 2005, to PetroQuest Energy, Inc. (the
“Company”) transmitting the comments of the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) relating to the above referenced Form 10-K, Form 10-Q and the comment
response letter dated May 3, 2005. The numbered paragraphs below correspond to the numbered
comments in your letter.

10-K for the fiscal year ended December 31, 2004

Note 1 — Organization and Summary of Significant Accounting Policies, page F-7

Derivative Instruments, page F-9

     1. In response to your comment, the Company advises the Staff that the Company’s commodity hedge
contracts are indexed to the same quantity of the same commodity over the same period of time and
in similar locations as the underlying production and sales of the Company’s Gulf Coast Basin oil
and gas. The hedges have a fair value of zero at inception. Specifically, our hedge contracts are
settled using NYMEX index pricing which is tied directly to the pricing at the Henry Hub and WTI
indexes which are in close proximity to the locations that the underlying production is marketed.
As a result, there is a high correlation between the

Mr. Karl Hiller

June 16, 2005

Page 2

historical settlement prices of derivative contracts and the historical realized prices received. We expect that these prices will continue to
be highly correlated. Based on the above factors, and the results of our hedge effectiveness
tests, we are able to conclude that in accordance with paragraph 65 of Section 2 of the
Implementation Guidance our hedges are highly effective. As a result, monthly hedge settlements
are recorded to oil and gas revenues as the ineffective portion is minimal and immaterial for
reclassification to derivative expense.

2. In response to your comment, the Company advises the Staff that it will disclose in future
filings the estimated amounts reported in Other Comprehensive Income that are expected to be
reclassified into earnings within the next 12 months. The Company supplementally advises the Staff
that as of March 31, 2005 and December 31, 2004, the Company’s accumulated comprehensive loss
included approximately $5.5 million and $2.9 million, respectively, of net deferred losses on
derivatives that are expected to be reclassified into oil and gas sales during the next 12 months
assuming no change in the forward commodity prices from prices used to calculate the fair value of
derivatives at March 31, 2005 and December 31, 2004. These derivative losses are expected to be
reclassified to earnings as the oil and natural gas volumes underlying the hedge contracts are
produced and sold.

In connection with the Company’s response to the Staff, the Company acknowledges that (i) it is
responsible for the adequacy and accuracy of the disclosure in this filing, (ii) Staff comments or
changes to disclosure in response to Staff comments do not foreclose the Commission from taking any
action with respect to this filing and (iii) the Company may not assert Staff comments as a defense
in any proceeding initiated by the Commission or any person under the federal securities laws of
the United States.

     I hope the foregoing materials are responsive to the Staff’s comments. Please call the
undersigned at (337) 272-7469 with any additional comments or questions you may have.

Regards,

/s/ Michael O. Aldridge

Michael O. Aldridge

Enclosures

    cc:

    Mr. Mark A. Wojciechowski

    Ms. Jennifer Gallagher