SecProbe.io

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                                 DIANE D. DALMY
                                 ATTORNEY AT LAW
                              8965 W. CORNELL PLACE
                            LAKEWOOD, COLORADO 80227
                                 (303) 985.9324
                           (303) 988.6954 (FACSIMILE)
                           EMAIL:DDALMY@EARTHLINK.NET

July 25, 2005

Mr. Karl Hiller, Branch Chief
Mr. John Weitzel, Staff Accountant
Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549

Via Facsimile: 202.772.9369

Re:    Lexington Resources, Inc.
       Form 10-KSB for year ended December 31, 2004
       Filed March 31, 2005
       Amended July 23, 2005
       File No. 0-25455

Dear Mr. Hiller:

On behalf of Lexington Resources, Inc., a Nevada corporation (the "Company"), we
submit the  following  responses  which  correspond  to the  numerical  comments
contained in the Securities and Exchange  Commission  letter dated July 12, 2005
(the "SEC  Letter") and  Amendment No. 1 to the annual report on Form 10-KSB for
fiscal  year ended  December  31,  2004 (the  "Annual  Report"),  which has been
accordingly  revised.  The response  letter  indicates the section of the Annual
Report in which our  revisions in response to the comments in the SEC Letter are
contained.

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Securities and Exchange Commission
Page Two
July 25, 2005

FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2004

INDEPENDENT AUDITOR

LOCATION OF AUDITOR - PAGE F-2

1.   Please be advised that the board of  directors  considered  several  issues
     regarding the  appointment  and  engagement  of Dale  Matheson  Carr-Hilton
     LaBonte  ("DMCHL")  as  the  Company's   independent  public   accountants,
     including the  requirements  under Article 2 of Regulation S-X. Some of the
     Company's management,  who are primarily responsible for the daily business
     and  financial  operations  of the Company,  reside in  Vancouver,  British
     Columbia.  Some of the members of the Company's audit  committee  reside in
     Vancouver,  British  Columbia.  Therefore,  this  has  provided  a  viable,
     efficient,  and cost-effective  working arrangement between the Company and
     its auditors relating to administration and accounting services.  Moreover,
     DMCHL has extensive  experience  pertaining  to the United  States  federal
     securities laws and is PCAOB registered. Management of the Company believes
     that it is in the best  interests  of the Company to engage an  independent
     public  accounting  firm that is mid-size and  therefore  responsive to the
     needs of a developmental but growing company. Lastly, the Company wishes to
     maximize application of funding to its U.S. based oil and gas interests and
     other applicable costs, and engagement of an independent  public accountant
     located in Vancouver allows payment for services  comprised of labor inputs
     denominated  in  Canadian  dollars  thus  decreasing  the amount of funding
     required for audit and review services.

AUDITOR'S REPORT, PAGE F-2

2.   In accordance with the SEC's comment,  the third paragraph of the auditor's
     report  has  been  revised  to  include  a  sentence  identifying  that the
     accounting  principles  generally  accepted in the United  States have been
     used in preparation of the Company's financial statements.

FINANCIAL STATEMENT FOOTNOTES

3.   In accordance  with the SEC's comment,  the financial  statements have been
     revised  by  providing  "Note 13.  Disclosure  About Oil and Gas  Producing
     Activities  (Unaudited) regarding  supplemental  disclosure for oil and gas
     properties as required by SFAS 69.

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Securities and Exchange Commission
Page Three
July 25, 2005

EXHIBIT 32.1 CERTIFICATION UNDER SECTION 906

4.   The  certifications  to the Annual Report have been dated as of the date of
     the amendment to the Annual Report.

In accordance with the SEC's request,  included is the  acknowledgment  from the
Company.

If you should have further questions or comments, please contact me at the
above-referenced contact information.

Sincerely,

/s/ DIANE D. DALMY
__________________
    Diane D. Dalmy

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