SecProbe.io

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							March 31, 2005

via facsimile and U.S. mail
W. Gordon Lancaster
Chief Financial Officer
Ivanhoe Energy, Inc.
654-999 Canada Place
Vancouver, British Columbia, Canada

	Re:	Ivanhoe Energy, Inc.
		10-K for the year ended December 31, 2004
      File No. 000-30586

Dear Mr. Lancaster:

      We have reviewed the above filing and have the following
accounting and engineering comments.  We have limited our review
to
the matters specifically identified below. 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
comments are inapplicable or 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 supplemental 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.

10-K for the year ended December 31, 2004

Notes to Consolidated Financial Statements

Note 19 Additional Disclosures Required Under U.S. GAAP, page 62

1. We note that you have not provided the disclosures required
under
Rule 4-10(c)(7)(ii) of Regulation S-X, regarding capitalized costs
excluded from amortization.  Please expand your disclosures to
address the following point:

(a)	Provide a description of the current status of the
significant
properties or projects for which costs are excluded from
amortization, and the anticipated timing of the inclusion of such
costs in the amortization computation.

Engineering Comment

Supplementary Disclosures About Oil and Gas Production Activities,
page 67

	Oil and Gas Reserves, page 67

2. We note that almost 86% of your reserves in China are
classified
as proved undeveloped and that these reserves represent almost 70%
of
your total reported reserves.  Supplementally, please provide us
with
the technical justification for these reserves.   This should
include
but not be limited to decline curves, structure maps with the
producing wells and proved undeveloped locations annotated on the
maps, volumetric calculations, example logs, fluid and rock
properties and that portion of the reserve report pertaining to
these
particular reserves.

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
amendments 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 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 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 the 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(s);

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 Jon Duersch at (202) 942-1761 or Karl Hiller
at
(202) 942-1981 if you have questions regarding comments on the
financial statements and related matters.  You may contact Jim
Murphy
at (202) 942-2935 if you have questions about the engineering
comment.  Please contact me at (202) 942-1870 with any other
questions.  Direct all correspondence to the following ZIP code:
20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director
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Ivanhoe Energy, Inc.
March 31, 2005
Page 1

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

         DIVISION OF
CORPORATION FINANCE

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