SecProbe.io

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

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

         DIVISION OF
CORPORATION FINANCE
							April 1, 2005

Via Facsimile and U.S. Mail

Mr. Michael Montgomery
Chairman of the Board and President
Trek Resources, Inc.
4925 Greenville Avenue, Suite 955
Dallas, Texas  75206

Re:	Trek Resources
Preliminary Proxy Materials amended on March 7, 2005
File No. 0-32491

Schedule 13E-3 amended on March 7, 2005
      File No. 5-78060

      Form 10-KSB for the year ended September 30, 2004
      Filed on December 29, 2004
      Draft amended materials dated March 7, 2005
      File No. 0-32491

Dear Mr. Montgomery:

      We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise your documents in
response to our 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
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.

Background of the Merger, page 14

1. You cite, in several locations, your inability (i) to access
the
capital markets and (ii) to use your stock as "consideration for
acquisition transactions."  Briefly describe what attempts you
have
made in the last year in either of those two areas.

Factors Considered by Our Board of Directors as to the Fairness of
the Reverse Stock Split, page 25

2. We note your response to prior comment 22.  Please further
expand
your disclosure to explain why your going concern value cannot be
determined with accuracy.

Accounting Comments

3. Please monitor the requirement to update the financial
statements
as required by Item 310(g) of Regulation S-B.
Closing Comments

	File amendments to the Form 10-KSB, Form 14C, and Schedule
13E-3
in response to these comments.  Please file clearly and accurately
marked copies of the amendments and include in your response
letter
page references to the amendments indicating where changes in
response to our comments are located.  Please also note the
location
of any material changes made for reasons other than in response to
our comments.  In the event you disagree with any of these
comments,
provide the basis in your response letter.  We may have additional
comments based on your responses.

	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 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.

	Direct any questions concerning any accounting issues to
Gabrielle Malits (202) 942-2873, or in her absence, to Kimberly
Calder, Assistant Chief Accountant, at (202) 942-1879.  Direct
questions relating to all other disclosure issues to Melinda
Kramer
at (202) 942-1938 or in her absence, to the undersigned at (202)
942-
1870.
      Sincerely,

								H. Roger Schwall
								Assistant Director

cc:	Melinda Kramer
	Gabrielle Malits
	Kimberly Calder
	Lillian Brown
??

??

??

??

Trek Resources, Inc.
April 1, 2005
Page 1

</TEXT>
</DOCUMENT>