SecProbe.io

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								June 14, 2005

Mr. Barry MacNeil
Chief Financial Officer
Trans-Orient Petroleum Ltd.
1407-1050 Burrard Street
Vancouver, British Columbia, Canada  V6Z 2S3

	Re:	Trans-Orient Petroleum Ltd.
		Form 20-F for Fiscal Year Ended July 31, 2004
Filed January 31, 2005
		File No. 0-27668

Dear Mr. MacNeil:

      We have reviewed your filing and have the following comment.
We
have limited our review of your filing to that issue we have
addressed
in our comment.   Where indicated, we think you should revise your
document in response to this comment.  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.

	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 comment or any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

Form 20-F for the Fiscal Year Ended July 31, 2004

Financial Statements

Auditors` Report

1. We note your auditors refer to another accountant in their
report.
Please include the predecessor accountants` report in your Form
20-F
as required by Item 8.A of Form 20-F.  Please note you may not
incorporate these reports as an exhibit in the Form 20-F.
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
the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your response to our comment 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 comment.

	 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 comment, 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 comment on your filing.

You may contact Ryan Milne at (202) 551-3688, or Jenifer Gallagher
at
(202) 551-3706, if you have questions regarding comment on the
financial statements and related matters.  Please contact me at
(202)
551-3684 with any other questions.

								Sincerely,

								April Sifford
								Branch Chief

cc: 	Mr. Ryan Milne
	Ms. Jenifer Gallagher
Mr. Barry MacNeil
Trans-Orient Petroleum Ltd.
June 14, 2005
Page 1

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

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 04-05

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