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PRIVILEGED AND CONFIDENTIAL

FOIA CONFIDENTIAL TREATMENT REQUEST

CONFIDENTIALITY REQUESTED PURSUANT TO RULE 83

Via Hand Delivery

November 14, 2005

H. Roger Schwall

Assistant Director

U. S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-7010

    Re:

    Stone Energy Corporation

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

    Filed March 9, 2005

    File No. 001-12074

    Press release dated October 6, 2005

Dear Mr. Schwall:

     Pursuant to your request, Stone Energy Corporation (“Stone”) is hereby providing (i) written
responses to the comments contained in your letter, dated October 21, 2005, and (ii) the materials
and other information requested in said letter. In addition to these responses, we note that Stone
issued a press release on November 8, 2005, and filed a Form 8-K and a Form 12b-25 on November 9,
2005, copies of which have been furnished to you, stating that Stone would restate certain
historical financial statements and provide selected financial data for the three and nine month
periods ended September 30, 2005 and the comparable periods of 2004 and would amend its Form 10-K
for the year ended December 31, 2004 and its quarterly reports on Form 10-Q for the periods ended
March 31, 2005 and June 30, 2005. Responses applicable to Form 10-K are based on data as
originally filed and do not reflect adjustments to be made in the restated financial statements to
be included in the amended Form 10K/A.

     Stone would also like to call your attention to the following paragraph in its November 8,
2005 press release:

“Stone and its audit committee are actively working to implement controls and procedures
that will ensure the integrity of the company’s reserve booking

Mr. H. Roger Schwall

Securities and Exchange Commission

November 14, 2005

Page 2

process. The following controls are either in place or are being implemented for reserve
booking: (i) improved training regarding SEC guidelines, (ii) revisions of documentation
procedures and controls, (iii) the continued use of one or more independent third party
engineering firms, (iv) the formation of a specific reserves committee of the board of
directors to review the reserve booking process, and (v) appointment of a reservoir
engineer as Vice President, Reserves. On November 4, 2005, Davis Polk & Wardwell issued a
preliminary oral report to the audit committee of Stone’s board of directors that was
critical of certain past reserve estimation and review practices and methodologies and made
recommendations consistent with the implementation of controls and procedures outlined
above. Davis Polk has been engaged by the audit committee to assist in its investigation of
Stone’s reserve revisions. Davis Polk advised the audit committee that its investigation
was not complete, but preliminary findings have indicated inadequate training and
understanding of the SEC requirements for booking reserves. Davis Polk also reported that
in the past there appears to have been a tone of optimism and aggressiveness set by
management regarding reserve booking.”

Responses to your October 21, 2005 comments:

Form 10-K for the Fiscal Year Ended December 31, 2004

Results of Operations, page 21

Reserves, page 22

    1.

    “You present the average oil and gas prices used in determining reserves excluding the
effects of hedges in place at year end. The guidance in SAB Topic 12(D)(3)(b) pertains to
derivative contracts that are accounted for as cash flow hedges under SFAS 133, and requires
hedge adjusted prices to be utilized in conducting the full cost ceiling test under Rule
4-10(c)(4) of Regulation S-X. Please comply with the requirements of this guidance, including
the disclosure provisions. If you believe no revision is necessary due to the absence of
different results applying this guidance, or regard the changes as immaterial, submit an
analysis supporting your view. Please ensure that you address the effect on the ceiling test,
as well as the effect on the Standardized Measure of Discounted Future Net Cash Flows.”

Response 1:

Stone believes no revision is necessary due to the absence of any different results from
applying this guidance. As disclosed in Footnote 9-Hedging Activities, the majority of
Stone’s hedges are zero-premium collars with floor and ceiling prices.

Mr. H. Roger Schwall

Securities and Exchange Commission

November 14, 2005

Page 3

Since Stone’s average year-end prices fall between all of the floor and ceiling prices,
there is no impact on the ceiling test with respect to these hedges. Regarding Stone’s
fixed price swaps, the computed impact is well below the excess of the ceiling over net
capitalized costs. This is demonstrated by the following supplemental information:

    Computed ceiling without effect of swaps

    $
    2,096,852,000

    Estimated effect of fixed price swaps

    ( 9,537,000
    )

    Ceiling with effect of fixed price swaps

    2,087,315,000

    Net capitalized costs (adjusted for deferred taxes)

    1,441,206,000

    Excess of ceiling over net capitalized costs

    646,109,000

The effect of fixed price swaps on Standardized Measure is also estimated to be $9,537,000.

Stone’s analysis of Topic 12(D)(3)(b) indicates the following recommended disclosures, if
applicable and material:

An indication of the effects of using cash flow hedges in calculating ceiling limitations.
Stone deems the effects to be immaterial (see analysis above).

The portion of future oil and gas production being hedged. Please be advised
supplementally that, based on projections of production at the time of the 10-K filing,
Stone estimates that it had hedged approximately 40% to 50% of its estimated 2005 Gulf
Coast oil and gas production and 50% to 60% of its estimated 2005 Rockies gas production.

The dollar amount that would have been charged to income had the effects of the cash flow
hedges not been considered in calculating the ceiling limitation. No disclosure was
necessary because there was no effect on income from using cash flow hedges in calculating
the ceiling limitation.

Consider the disclosure requirements under SOP 94-6. Stone considered the disclosure
requirements of SOP 94-6 and determined them to be immaterial in this instance.

Financial Statements

Consolidated Statement of Cash Flows, page F-5

    2.

    “Your adjustments to reconcile net income to net cash provided by operating activities do not
include a reconciling item related to payables. The guidance in SFAS 95 paragraph 29 requires
the reconciliation to include among other things,

Mr. H. Roger Schwall

Securities and Exchange Commission

November 14, 2005

Page 4

changes in payables pertaining to operating activities. Tell us the reasons you believe
you would not need to revise your Statement to comply with the requirements of SFAS 95.”

Response 2:

The vast majority of expenditures for Stone running through its payable system are capital
in nature. For 2004, Stone estimates that approximately $500,000 of the change in payables
related to operational activities. We believe this amount is immaterial. Stone will
continue to monitor the materiality of this item in future filings.

Note 9 – Hedging Activities, page F-17

    3.

    “Please disclose the estimated amount of unrealized gains or losses expected to be
reclassified into earnings within the next 12 months to comply with the guidance in SFAS 133,
paragraph 45(b)(2).”

Response 3:

As indicated in its balance sheet and disclosed in its footnotes, all of Stone’s hedges at
December 31, 2004 will be settled within twelve months and are classified as current assets
or liabilities. In the uncertain arena of commodity price prediction, the market forces
that determine the fair value of these hedges are the best estimate of what these hedges
will eventually be settled for when the time frame is that short. Consequently, Stone’s
opinion is that the balance sheet and footnote presentations satisfy the requirements of
SFAS 133 paragraph 45(b)(2).

Note 4 – Investment in Oil and Gas Properties, page F-14

    4.

    “Your table of unevaluated costs does not appear to include the amounts related to
capitalized interest which you identify on page F-9. As such, it appears you may need to
revise the table to include the amount of capitalized interest in each of the respective
years. Additionally, you should provide a description of the current status of the
significant properties or projects excluded from amortization, and the anticipated timing of
including the costs in the amortization computation, to comply with Regulation S-X Rule
4-10(c)(7).”

Response 4:

Stone’s table of unevaluated costs on page F-14 does include amounts related to capitalized
interest, which are identified on page F-9. The table of unevaluated costs includes
acquisition and exploration costs. Each of these categories includes

Mr. H. Roger Schwall

Securities and Exchange Commission

November 14, 2005

Page 5

amounts related to capitalized interest for each period indicated. In the table on page
F-14, the balance of unevaluated costs, as of December 31, 2004, agrees with the amount of
unevaluated oil and gas properties indicated on the face of the balance sheet.
Consequently, Stone believes its table of unevaluated costs on page F-14 needs no revision.

On page F-9, Stone states it believes a majority of its unevaluated properties will be
evaluated within 48 months. Stone believes that this is adequate disclosure given the fact
that there was no individual property or project excluded from the amortization base over
12% of total unevaluated costs at December 31, 2004.

Engineering Comments

Form 10-K for the Fiscal Year Ended December 31, 2004

Risk Factors, page 7

    5.

    “We could find no risk factor disclosing the risk you face from hurricanes in the Gulf of
Mexico which you stated is the only reason for your decline in production in 2004. As
approximately 90% of your reserves and production are in the Gulf of Mexico, include a risk
factor disclosing the risks you face and how this risk has specifically affected your previous
results as to production, loss of revenues and costs of repairs from hurricanes and other
major storms in the Gulf of Mexico.”

Response 5:

On page 7 of the 2004 10-K, Stone disclosed “weather” as being a risk factor for its
business. In future filings, Stone will specify “hurricanes” as a specific weather risk.
Stone intends to add a disclosure with respect to Hurricane Ivan to the risk factor on
weather risk.

As supplemental information, please be advised that in 2004, we estimated that we lost
approximately 7.0 Bcfe in volumes tied to the disruption from Hurricane Ivan. This
represented approximately 8% of our total production for the year. Without these
disruptions, we would have experienced an annual production decline of approximately 2%.
Applying the prevailing oil and gas prices at the time, we estimate the lost revenue was
approximately $43 million. The cost of the repairs through December 31, 2004 was
approximately $8 million.

Properties, page 13

    6.

    “Provide more detailed reserve and production information. Indicate what percentage of your
reserves and production is from which geographic area or

Mr. H. Roger Schwall

Securities and Exchange Commission

November 14, 2005

Page 6

individually significant fields. See Item 102 of Regulation S-K and Instruction 3 to Item
102 as to the required disclosure of production, reserves, locations, development and the
nature of your interest for your significant properties. Note the SEC’s EDGAR program now
accepts digital maps, so please include these as necessary.”

Response 6:

The following table describes Stone’s production and reserve information by geographic
location and is being provided as supplemental information in response to the Staff’s
comment:

STONE ENERGY CORPORATION

STATISTICS BY REGION

TWELVE MONTHS ENDED DECMEBER 31, 2004

    Reserves (Mcfe)

    Production Volumes (Mcfe)

    Gulf of Mexico

    736,981,300

    89
    %

    80,650,453

    91
    %

    Rocky Mountains

    87,968,500

    11
    %

    7,521,989

    9
    %

    Total

    824,949,800

    100
    %

    88,172,442

    100
    %

Although Stone does not specifically present a table of reserve and production information
by geographic area in its 2004 Form 10-K, it does indicate in Item 1 of the 10-K that Rocky
Mountain properties represent less than 11% of total production and reserves. Productive
well and acreage data by geographic area included in Item 2 of the 10-K. Item 102 of
Regulation S-K requires the nature of Stone’s interest for its significant properties be
disclosed. In its 2004 Form 10-K, Item 2 — Properties, Stone does disclose its percentage
of operatorship on its significant properties. Enclosed herewith is a map, dated November
9, 2005, showing Stone Gulf of Mexico properties, both operated and non-operated, with an
inset showing Stone Rocky Mountain properties.

Oil and Natural Gas Reserves, page 14

    7.

    “We note that you used four different third-party engineers in 2004 to determine your proved
reserves. Indicate which independent third-party engineering firm worked on what part of your
reserves and the percentage of your overall reserves they evaluated.”

Response 7:

Mr. H. Roger Schwall

Securities and Exchange Commission

November 14, 2005

Page 7

As supplemental information, please be advised that the total percent of the reserves
evaluated by each consultant was: Atwater Consultants, Ltd. (“ACL”) – 76.00% (offshore and
onshore Gulf of Mexico), Cawley, Gillespie & Associates, Inc. (“CGA”)– 4.27% (onshore
Louisiana), Netherland, Sewell & Associates, Inc. (“NSA”) – 9.07% (offshore Gulf of
Mexico), and Ryder Scott Company, L.P. (“RS”) – 10.66% (Rocky Mountains).

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
20

    8.

    “We note that in the 2004 10-K report in the MD&A you informed investors that your 9% overall
decrease in production for 2004 compared to 2003, was the result of extended downtime from
Hurricane Ivan. Tell us when your Gulf of Mexico production was fully restored from the
effects of Hurricane Ivan and what the production was at the first of the year, just prior to
the Hurricane and after production had been fully restored. Tell us if production in your
other geographical areas declined from year-end 2003 to year-end 2004 and if so by how much.”

Response 8:

The following information is being provided supplementally in response to the Staff’s
comment: Gulf of Mexico production was not fully restored from Hurricane Ivan until the
second quarter of 2005. Average daily production for the first quarter of 2004 was 263
mmcfe per day. Average daily production for the months of July and August 2004 (the months
immediately prior to Hurricane Ivan) was 247 mmcfe per day. Average daily production for
the second quarter of 2005 (the first quarter when production from Hurricane Ivan had been
fully restored) was 285 mmcfe. There were no declines in production in Stone’s other
geographical areas (other than the Gulf of Mexico) from year-end 2003 to year-end 2004.

    9.

    “We note that since 2002 your overall production rate has declined by over 15% and therefore,
your statement in the 2004 10-K that your production decrease was solely due to weather
appears to be incorrect. Tell us how you plan to provide investors with correct information
about your past and future production rates.”

Response 9:

Stone stated the following in its MD&A: “The decrease in overall 2004 production, compared
to 2003, was primarily the result of extended production downtime from Hurricane Ivan.”
Please be advised supplementally that our estimates of the effects of Hurricane Ivan were
approximately 7.0 Bcfe of the

Mr. H. Roger Schwall

Securities