SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                                                      August 31,
2005

Mail Stop 4561

John M. James
303 West Wall Street, Suite 2300
Midland, TX

      Re:	AMEN Properties, Inc.
		Form 10-KSB for the year ended December 31, 2004
	Forms 10-QSB for the quarters ended March 31, 2005 and June
30,
2005
		File No. 000-22847

Dear Mr. James:

      We have reviewed your above referenced filings and have the
following comments.  We have limited our review to only the issues
addressed below and will make no further review of your documents.
As such, all persons who are responsible for the adequacy and
accuracy of the disclosure are urged to be certain that they have
included all information required pursuant to the Securities
Exchange
Act of 1934.

      Where indicated, we think you should revise your documents
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 information
so
we may better understand your disclosure.  After reviewing this
information, we may or may not 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 on 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 year ended December 31, 2004

Item 8a Controls and Procedures, page 26

1. We note your disclosure that management has identified certain
matters involving internal control deficiencies the Company has
concluded that, "...except as noted above the Company`s current
disclosure controls and procedures are sufficient to timely alert
..."  It remains unclear how you considered the identified
internal
control deficiencies in reaching the conclusion that your
disclosure
controls and procedures are effective.  If true, you can state
that
your disclosure controls and procedures are effective including
consideration of the identified matters, so long as you provide
appropriate disclosure explaining how the disclosure controls and
procedures were determined to be effective in light of the
identified
matters.  Or, if true, you can state that given the identified
matters, your disclosure controls and procedures are not
effective.
Please revise as appropriate.

2. We note your disclosure that "Other than arising from the
review
described below, there have not been changes in internal
control..."
You should state clearly, if correct, that there were changes in
your
internal control over financial reporting that occurred during
this
quarter that have materially affected or are reasonably likely to
materially affect, your internal control over financial reporting.

Financial Statements

Note C - Disposition of Assets, page 14

3. Explain to us how the guidance in SFAS 144 supports the
presentation of the operations of the Lubbock office building in
continued operations for the year ended December 31, 2004.

*    *    *    *

      As appropriate, please amend your filings 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 supplemental information.  Detailed cover
letters greatly facilitate our review.  Please file your cover
letter
on EDGAR.  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 filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Robert Telewicz, Staff Accountant, at (202)
551-3438 or the undersigned at (202) 551-3414 if you have
questions.

							Sincerely,

            Jorge Bonilla
      Senior Staff Accountant

??

??

??

??

Mr. John M. James
Amen Properties, Inc.
August 31, 2005
Page 1

</TEXT>
</DOCUMENT>