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      HOUSTON
AMERICAN ENERGY CORP.

      801
TRAVIS, SUITE 1425

      HOUSTON,
TEXAS 77002

      TELEPHONE
(713) 222-6966

      FACSIMILE
(713) 222-6440

      January
14, 2010

      U.S.
Securities and Exchange Commission

      100 F
Street, N.E.

      Washington,
D.C. 20549

                Attn:

                Parker
      Morrill

                RE:

                Houston
      American Energy Corp.

                Form
      10-K for Fiscal Year Ended December 31,
2008

                Filed
      March 16, 2009

                Definitive
      Proxy Statement filed on Schedule
14A

                Filed
      April 27, 2009

                File
      No. 1-32955

      Dear Mr.
Morrill:

      Please
find the following responses to the Staff’s letter, dated December 30, 2009, to
Houston American Energy Corp. (the “Company”).

      Per the
discussion of January 11, 2010 among yourself and Michael Sanders, our counsel,
we propose to address each of the comments herein through appropriate
incorporation into our future filings as opposed to filing amendments to our
Form 10-K and Proxy Statement referenced above.  We believe such
approach is appropriate given the fact that we will be filing our 2009 Form 10-K
and annual Proxy Statement in the near future and our belief that the comments
in question, and resulting amendments, are minimal in nature.  It is
our belief that the investing public will derive little, if any, benefit from
amending our prior filings as those filings will be outdated by the more current
information included in our upcoming 2009 Form 10-K and Proxy Statement filings
and, therefore, the amendment of prior filings would not be of material benefit
to the investing public.

      Set forth
below are the comments included in the Staff’s December 30, 2009 letter followed
by our responses.

      Form
10-K

      Natural Gas & Oil
Reserves, page 8

                1.

                You
      state “the reserve data contained in this report represent only
      estimates.” Revise your disclosure to clarify that proved reserves are
      quantities that the company is reasonably certain of obtaining or delete
      those quantities.

      U.S.
Securities and Exchange Commission

      January
14, 2010

      Page
2

      Company
Response:

      The
Company proposes, in future filings, to delete the referenced language and to
replace the same with the following language “The
reserve data contained in this report represent quantities that the company is
reasonably certain of obtaining.”

      Results of Operations, page
27

                2.

                To
      the extent practicable, quantify the impact of each of the factors cited
      as contributing to the increase in revenue.  We note the
      reference to “principally due.”

      Company
Response:

      The
Company proposes, in future filings, to provide additional information with
respect to period to period changes in production volumes and average sales
prices to assist readers in quantifying the impact of factors affecting
revenues.  Such information is reflected in the Company’s 2009 Form
10-Qs.  Where specific factors can be further quantified by isolating
individual factors, the Company will provide further details to quantify the
impact of each such factor.

      As an
example, the current discussion of revenues appearing in the first four
paragraphs under Oil and Gas
Revenues beginning on the bottom of page 27 and continuing on page 28
through the Hydrocarbon Price table, would be revised and expanded to read as
follows:

      Oil and Gas Revenues. Total
oil and gas revenues increased $5,644,878, or 113.4%, to $10,622,050 in fiscal
2008 compared to $4,977,172 in fiscal 2007.

      The
increase in oil and gas revenue is due to increased oil production (up 52,720
barrels or 74%, or approximately $4.4 million based on average oil prices
realized during 2008) resulting from the development of the Colombian fields and
higher average oil prices during 2008 ($1.3 million), partially offset by
decreased natural gas production ($0.1 million).

      The
change in production volumes reflects increased production in fields in which we
hold higher working interests (12.5% vs. 1.6% in Caracara) which more than
offset a decrease in production from the Caracara concession resulting from our
sale of our interest in the same during the second quarter of
2008.  Oil production from the Caracara prospect totaled 29,954
barrels during 2008, through the sale of the prospect in June of 2008, as
compared to 56,705 barrels during the 2007 full fiscal year.

      During
2008, we had interests in 45 producing wells in Colombia, including the 34
Caracara wells, and 6 producing wells in the U.S as compared to 39 producing
wells in Colombia and 7 producing wells in the U.S. during
2007.

      U.S.
Securities and Exchange Commission

      January
14, 2010

      Page
3

      The
following table sets forth a comparison of net oil and gas production and
hydrocarbon prices for 2008 and 2007:

                2008

                2007

                Net
      gas production (Mcf)

              24,748

              44,250

                Net
      oil production (Bbls)

              123,925

              71,205

                Oil—Average
      price per barrel

              $
              83.67

              $
              65.61

                Gas—Average
      price per mcf

              $
              10.22

              $
              6.90

      Control and
Procedures

      Changes in Internal Control
over Financial Reporting, page 35

                3.

                You
      disclose that “Except as noted above, no change in our internal control
      over financial reporting (as defined in Rule 13a-15(f) under the
      Securities Exchange Act of 1934) occurred during the fourth quarter of
      fiscal 2008 that has materially affected, or is reasonably likely to
      materially affect, our internal control over financial
      reporting.”  Please modify your disclosure to state clearly, of
      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.  In this regard, we do not believe the
      guidance in Item 308(c) of Regulation S-K allows for such qualifying
      language in the disclosure.

      Company
Response:

      The
Company proposes, in future filings and to the extent applicable, to delete the
referenced language.  As a result, the disclosure will simply state
(as is the case excluding the language in question) the change(s), if any, that
occurred during the applicable quarter.

      Schedule
14A

      Executive Compensation, page
6

                4.

                We
      note that the NEOs received stock and option awards in
      2008.  Please provide the Grants of Plan-Based Awards Table set
      forth in Regulation S-K, Item
402(d).

      Company
Response:

      The
Company proposes, in future filings, to assure that the Grants of Plan-Based
Awards Table set forth in Regulation S-K, Item 402(d) will be included in its
proxy statement, or Form 10-K, as appropriate.

      U.S.
Securities and Exchange Commission

      January
14, 2010

      Page
4

      As an
example, in the Proxy Statement in question, immediately following the Summary
Compensation Table, the following table would be inserted:

      Grants of Plan-Based Awards
in Fiscal Year 2008

      The following table sets forth
information concerning annual incentive awards, stock options, restricted stock
units and performance units granted during fiscal year 2009 to each of the named
executive officers:

                  Estimated
      Future Payouts Under

                  Non-Equity
      Incentive Plan Awards

                  Estimated
      Future Payouts Under

                  Equity
      Incentive Plan Awards

                  Name

                  Grant
      Date

                  Threshold

                  ($)

                  Target

                  ($)

                  Maximum

                  ($)

                  Threshold

                  (#)

                  Target

                  (#)

                  Maximum

                  (#)

                  All

                  Other

                  Stock

                  Awards:

                  Number
      of

                  Shares
      of

                  Stock
      or

                  Units
      (#)(1)

                  All
      Other

                  Option

                  Awards:

                  Number
      of

                  Securities

                  Underlying

                  Options

                  (#)(2)

                  Exercise
      or

                  Base
      Price

                  of
      Option

                  Awards

                  ($/Sh)

                  Grant

                  Date
      Fair

                  Value
      of

                  Stock
      and

                  Option

                  Awards

                  ($)(3)

                  John
      Terwilliger

                  6/2/2008

                —

                —

                —

                —

                —

                —

                41,700

                —

                —

                300,240

                  6/2/2008

                —

                —

                —

                —

                —

                —

                —

                900,000

                7.20

                4,569,640

                  Jay
      Jacobs

                  6/2/2008

                —

                —

                —

                —

                —

                —

                13,900

                —

                —

                100,080

                  6/2/2008

                —

                —

                —

                —

                —

                —

                —

                150,000

                7.20

                729,573

                (1)

                Reflects
      the number of restricted stock units awarded in fiscal year 2008. For
      accounting purposes, the 2008 annual restricted stock unit awards have a
      grant date of June 2, 2008. This date is based on the date the approval by
      the shareholders of awards approved by the Compensation Committee on July
      2, 2007 subject to such shareholder approval. The awards vested in full on
      July 2, 2007, being the later of one year from the date of approval of the
      grants by the Compensation Committee or the date of approval by the
      shareholders.

                (2)

                Reflects
      the number of stock options awarded in fiscal year 2008. Stock options
      vest (a) with respect to Mr. Terwilliger, one-sixth on each of the first
      six anniversaries of the grant date, and (b) as to Mr. Jacobs, one-third
      on each of the first three anniversaries of the grant
  date.

                (3)

                The
      amounts included in the Grant Date Fair Value of Stock and Option Awards
      column represent the grant date fair value of the awards made to named
      executive officers in fiscal year 2008 in accordance with SFAS No. 123(R).
      The value ultimately realized by the executive upon the actual vesting of
      the award(s) or the exercise of the stock options may or may not be equal
      to the SFAS No. 123(R) determined
value.

                5.

                In
      2008, you awarded an “event specific bonus.”  Please explain
      what types of events qualify for this type of bonus.  Discuss
      the criteria that must be met or the factors considered before awarding
      this type of bonus.  Clarify why “the compensation committee
      determined that the sale of the company’s interest in the Caracara
      prospect represented the ultimate measure of performance of the management
      team in creation of shareholder value.”  Explain how the amount
      of the bonus is determined.

      U.S.
Securities and Exchange Commission

      January
14, 2010

      Page
5

      Company
Response:

      The
Company proposes, in future filings, to assure that the CD&A discussion
includes, as appropriate, a full discussion of (i) the types of events
qualifying for “event specific bonuses,” (i) the factors considered in making
such awards, and (iii) how the amount of such bonuses are
determined.

      As an
example, the Proxy Statement in question would be revised to reflect the above
matters as they relate to the 2008 bonuses as follows:

      Event
specific bonuses may be paid when the efforts of management produce results that
the Compensation Committee deems to be extraordinary.  Specifically,
acquisitions and dispositions, entry into material agreements and execution of
material financing transactions are evaluated by the Compensation Committee to
determine the propriety of paying “event specific bonuses.”  The
Compensation Committee will generally only consider paying such an “event
specific bonus” where the transactions or relationships in question reflect
current or past extraordinary efforts or contributions by the management team as
distinguished from transactions that arise organically from the Company’s
existing operations, assets or relationships.  The Compensation
Committee believes that such “event specific bonuses” are appropriate given the
entrepreneurial nature of our business, the small size of our management team
and our dependence upon our management team to source opportunities and
relationships.

      Generally,
an “event specific bonus” will only be paid after the Company has realized a
tangible measureable benefit from the specific events identified by the
Compensation Committee.  In the case of the “event specific bonus”
paid based on the sale of the Caracara assets, the management team made a case
to the Compensation Committee that the sale represented an extraordinary return
on invested capital and an accelerated realization of the value of the assets in
question without the need to invest additional capital or exposure of the
Company to operating and market risks.  The Compensation Committee
agreed with that assessment, noting that the Company’s CEO had personally
sourced the Caracara opportunity and established and nurtured the relationships
that led to the Company’s investment in the Caracara prospect.

      In
determining the amount of “event specific bonuses” to be paid in relation to the
Caracara sale, the Compensation Committee did not apply any specific formula but
attempted to arrive at an amount that would properly recognize and reward the
management team for their efforts, taking into account the realized benefits to
the Company, and provide the prospect of future bonuses as incentive to
management to provide future efforts to seek out opportunities with the
potential to produce superior returns on invested capital for the
Company.

      The
Compensation Committee balances the desire to fix bonuses at levels intended to
reward and provide incentive for extraordinary efforts with a desire to preserve
the vast majority of the value derived from those efforts for the
shareholders.  To that end, the Compensation Committee rejected a
recommendation from the management team that bonuses totaling $900,000 should be
paid upon consummation of the Caracara sale and, instead, determined that total
bonuses in that regard should be capped at a rounded amount approximating 6.5%
of the sales proceeds received from the Caracara sale.  The
Compensation Committee determined that a 93.5% / 6.5% sharing ratio would both
adequa