SEC Comment Letter for SM Energy Co (SM) (CIK 0000893538) (SM) — Mar 17, 2008

SM Energy Co (SM) (CIK 0000893538)
Date: March 17, 2008 · CIK: 0000893538 · Accession: 0000000000-08-013938

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File numbers found in text: 001-31539

Date

February 5, 2008

Author

Carmen Moncada-Terry

Form

UPLOAD

Company

SM Energy Co (SM) (CIK 0000893538)

Letter

February 5, 2008 Mail Stop 7010 By U.S. Mail and facsimile to (303) 861-0934 David W. Honeyfield Senior Vice President – Chief Financial Officer St. Mary Land & Exploration Company 1776 Lincoln Street, Suite 700 Denver, Colorado 80203 Re: St. Mary Land & Exploration Company Definitive Proxy Statement on Schedule 14A Filed April 10, 2007 File No. 001-31539

Dear Mr. Honeyfield: We have completed our review of your executive compensation and related disclosure, and we have no further comments at this time. Please note that the company is responsib le for the adequacy and accuracy of the disclosure in its filing. We are not approving any proposed disclosure you may have included in your response letter[ s] or any disclosure you include in your future filings in response to our comments.

If you have any further questions regardi ng our review of your filing, please call me at (202) 551-3687. S i n c e r e l y , C a r m e n M o n c a d a - T e r r y A t t o r n e y A d v i s o r

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February 5, 2008
 Mail Stop 7010
By U.S. Mail and facsimile to (303) 861-0934

David W. Honeyfield Senior Vice President – Chief Financial Officer
St. Mary Land & Exploration Company 1776 Lincoln Street, Suite 700 Denver, Colorado 80203
 Re:  St. Mary Land & Exploration Company  Definitive Proxy Statement on Schedule 14A   Filed April 10, 2007  File No. 001-31539

Dear Mr. Honeyfield:
  We have completed our review of your executive compensation and related
disclosure, and we have no further comments at this time.
  Please note that the company is responsib le for the adequacy and accuracy of the
disclosure in its filing.  We  are not approving any proposed  disclosure you may have
included in your response letter[ s] or any disclosure you include  in your future filings in
response to our comments.

If you have any further questions regardi ng our review of your filing, please call
me at (202) 551-3687.           S i n c e r e l y ,            C a r m e n  M o n c a d a - T e r r y          A t t o r n e y  A d v i s o r

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