SecProbe.io

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

							March 21, 2005

Mail Stop 0304

Mr. Michael J. Ricketts
Chief Financial Officer and Principal Accounting Officer
Cano Petroleum, Inc.
The Oil & Gas Commerce Building
309 West 7th Street, Suite 1600
Fort Worth, TX  76102

	Re:	Cano Petroleum, Inc.
		June 30, 2004 Form 10-KSB
		September 30, 2004 Form 10-QSB/A
		December 31, 2004 Form 10-QSB
File No. 0-50386

Dear Mr. Ricketts:

We have reviewed the financial statements included in your filing
and
have the following comments.  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 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.

Financial Statement Comments

June 30, 2004 Form 10-KSB

Acquisition of Davenport

1.  Based upon the description of the transaction, it appears that
the acquisition of Davenport on May 24, 2004 should be presented
as a
reverse acquisition and reflected in the financial statements as a
recapitalization.  The acquisition is equivalent to the issuance
of
stock by Davenport for the net monetary assets of the public shell
corporation, accompanied by a recapitalization.  The accounting is
identical to that resulting from a reverse acquisition except no
goodwill or other intangible asset should be recorded.  For
accounting purposes, Davenport is the acquirer.

2.  The financial statements should present the historical
operations
of Davenport prior to the merger.  The Davenport stockholders`
equity
section should be retroactively restated to give effect to the
legal
structure of the former Huron Ventures with an offsetting entry to
additional paid in capital.  The retained earnings/deficit of
Davenport should be carried forward and adjusted for any
transaction
costs.  The issuance of common shares should be recorded at book
value rather than fair value.  We note the Company has recorded
goodwill from the transaction and the financial statements do not
reflect the accumulated deficit and results of operations of
Davenport prior to the transaction.  Please revise the financial
statements and related data to eliminate goodwill and adjust the
equity accounts as indicated.  Include footnote disclosure
describing
the accounting and reporting for the recapitalization.

3.  Please file a revised Form 10-KSB that includes a discussion
of
the reverse acquisition and the effects of the restatement on the
financial statements.  All of the historical disclosure required
by
Regulation S-B should be provided for Davenport as if it were the
registrant.  The auditors` report on the financial statement
should
make reference to the fact that the financial statements are
restated.  Pro forma disclosures for a recapitalization
transaction
may not be material.  Commencing with the periodic reports for the
year in which the Merger was consummated, all reports should be
filed
based on the fiscal year of Davenport.  The company`s subsequent
Exchange Act Reports should be revised so as to conform to the
above-
described presentation.

September 30, 2004 Form 10-QSB/A and December 31, 2004 Form 10-QSB

4.  Please expand Note 3 to explain why the acquisition of Ladder
was
effective May 1, 2004 yet does not appear to have been reflected
in
the company`s June 30, 2004 Form 10-KSB.

Closing Comments

Please make appropriate revisions in your filings in response to
these comments.  You may wish to provide us with marked copies of
the
amendments to expedite our review.  Please furnish a cover letter
with your revisions that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review. These revisions and the
letter
should be filed on EDGAR no later than April 5, 2005.  Please
understand that we may have additional comments after reviewing
your
revisions 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.  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 in the filings reviewed by the staff 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.

Any questions regarding the comments may be directed to Maureen
Bauer, Accountant at (202) 942-1824 or Ed Loftus, Assistant Chief
Accountant at (202) 942-2954.  In this regard, please do not
hesitate
to contact the undersigned or John Reynolds, Chief at (202) 942-
2999,
who supervised the review of your filing.

							Sincerely,

							Tia Jenkins
							Senior Assistant Chief
Accountant
      Office of Emerging Growth Companies

??

??

??

??

Cano Petroleum, Inc.
Page 3

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

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>