SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
February 2, 2007

By U.S. mail and facsimile

Mr. Dana Coffield
President and Chief Executive Officer
Gran Tierra Energy Inc.
300, 611-10th Avenue S.W.
Calgary, Alberta T2R 0B2, Canada

Re: Gran Tierra Energy Inc.
Amendment No. 4 to Registrati on Statement on Form SB-2
 Filed January 17, 2007
 File No. 333-132352
 Form 10-KSB, as amended, for the fiscal year ended December 31,
 2005
 Form 10-QSB, as amended, for th e fiscal quarter ended September
 31, 2006
 File No. 333-111656

Dear Mr. Coffield:

We have reviewed your filings and have the following comments.   Where
indicated, we think you should re vise your documents 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 deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.

 Please understand that the purpose of our re view 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 any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr.  Dana Coffield
Gran Tierra Energy Inc.
February 2, 2007 Page 2
Form SB-2/A4

Management’s Discussion and Analysis

Plan of Operations, page 32

1. Please update your plan of operations for 2007.

Subsequent Events, page 35

2. If material, please describe the minimu m work obligations for the property you
own in Peru which has received final ratification by the government of Peru.

Oil and Gas Properties-Argentina

Nicatimbay, page 48

3. Please update the information in regard to  the status of the Nacatimbay property.
We note that you say that you will be assessing the potential of the block in 2006.

Directors, Executive Officers, Promoters and Control Persons

Executive Officers and Directors, page 55

4. We note your addition of a biography for your new CFO, Mr. Eden.  In his
biography, please add the month in which he began and ended the positions listed
for him for the past five years.

Closing Comments

As appropriate, amend the registration st atement in response to these comments.
You may wish to provide us with marked c opies of the amendmen ts to expedite our
review.  Please furnish a cover letter with your amendments that keys your responses to
our comments and provides any requested in formation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendments and responses to our comments.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain th at the filing includes all information required
under the Securities Act of 1933 and that they have provide d all information investors
require for an informed investment 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.

Mr.  Dana Coffield
Gran Tierra Energy Inc.
February 2, 2007 Page 3
  Notwithstanding our comments, in the ev ent the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:

• should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

• the action of the Commission or the staff,  acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy  and accuracy of the disclosure in the filing; and

• the company may not assert staff comment s and the declaration of effectiveness
as a defense in any proceeding initiat ed by the Commission or any person under
the federal securities laws of the United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.

 We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.

 We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ade quate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.

  Please contact Donna Levy at (202) 551-3292 or me at (202) 551-3745 with any
questions.

Sincerely,

H. Roger Schwall
Assistant Director

cc: Jason Scott, Esq. (facsimile: 704-353-6181)
Donna Levy