SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
								November 28, 2005

Sent by US Mail and Facsimile to
Mr. Thomas B. Lovejoy
Chief Financial Officer
3006 Highland Drive, Ste 206
Salt Lake City, Utah 84106

	Re:	FX Energy, Inc.
		Form 10-KSB for Fiscal Year Ended December 31, 2004
		File No. 0-25386

Dear Mr. Lovejoy:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  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 some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

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

Engineering Comments

Business and Properties, page 4

	Project Area Summary, page 5

		Wilga, page 6

1. You state that you plan to place this well into commercial
production as soon as you have negotiated an acceptable gas
contract
with a suitable buyer.  Tell us if you have attributed proved
reserves to this well and if so, how much.  If you have attributed
proved reserves tell us the status of the effort to obtain a
contract
or the terms of your gas contract.  We may have further comment.

Exploration, Development, and Production Activities, page 7

      Exploratory Activities in Poland, page 67

		Fences I Project Area, page 7

2. Please amend you document to remove the reference to 40 BCF of
recoverable in Fences I and wherever else you reference unproved
reserves.  Also, please confirm that in future filings you will
only
disclose reserves that meet the definition of proved reserves as
found in Rule 4-10(a) of Regulation S-X.

Management`s Discussion and Analysis of Financial Condition and
Results of
Operation, page 22

	Introduction, page 22

3. You state that you are committed to pursuing an active
exploration
program in Poland but that you recognize you specific goals do not
necessarily coincide with those of your partners.   Please amend
your
document and expand your disclosure to clarify what the
differences
in your goals are and how this may affect your results in the
future.

Supplemental Information, page F-26

	Disclosure About Oil and Gas Properties and Producing
Activities, page F-26

		Summary Oil and Gas Reserve Data, page F-27

			Estimated Quantities of Proved Reserves, page F-27

4. In order to book proved reserves you must satisfy technical and
commerciality requirements.  It appears that your Polish gas
reserves
have satisfied the technical requirements however, it does not
appear
that you have satisfied the commerciality requirements.  In the
section of the 10-K called Market and Price Risk you state that
the
limited volume and source of your gas production means that you
cannot assure uninterruptible production or production in amounts
that would be meaningful to industrial users.  You also state that
there is no competitive market for the sale of gas in Poland and
we
also note that 90% of your "proved" Polish gas reserves are
undeveloped.  Therefore, until you can demonstrate the existence
of
approved gas contracts large enough to make the monetization of
your
undeveloped reserves reasonably certain these volumes do not
qualify
as proved at this time and should be removed from your filing.

Closing Comments

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

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* 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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

	You may contact James Murphy, Petroleum Engineer, at (202)
551-
3703 with questions about engineering comments.  Please contact me
at
(202) 551-3740 with any other questions.

								Sincerely,

								H. Roger Schwall
								Assistant Director

??

??

??

??

Mr. Thomas Lovejoy
FX Energy, Inc.
November 28, 2005
page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F STREET NE
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

</TEXT>
</DOCUMENT>