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SEC Comment Letter for GRAN TIERRA ENERGY INC. (GTE) (CIK 0001273441) (GTE) — Jan 9, 2013

GRAN TIERRA ENERGY INC. (GTE) (CIK 0001273441)
Date: Jan. 9, 2013 · CIK: 0001273441 · Accession: 0000000000-13-001389

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: October 10, 2012

Date
January 9, 2013
Author
/s/ Brad Skinner
Form
UPLOAD
Company
GRAN TIERRA ENERGY INC. (GTE) (CIK 0001273441)

Letter

January 9, 2013 Via E -Mail Mr. James Rozon Chief Financial Officer Gran Tierra Energy Inc. 300, 625 11 th Avenue SW Calgary, Alberta Canada T2R 0E1

Re: Gran Tierra Energy Inc. Form 10-K for Fiscal Year Ended December 31, 2011 Filed February 27, 2012 Response Letter Dated October 10, 2012 File No. 1-34018

Dear Mr. Rozon :

We have reviewed your response letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the request ed response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2011

Proved Undeveloped Reserves, page 18

1. We note your response to comment one which indicates that you converted 3.9 MMBOE of prove d undeveloped reserves and added 4.6 MMBOE of PUDs in Colombia. Please quantify the amount of investments to convert the 3.9 MMBOE and tell us how you expect to comply with Item 1203 of Regulation S -K.

Mr. James Rozon Gran Tierra Energy Inc. January 9, 2013 Page 2

You may contact John Cannarella at (202) 551 -3337 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3489 with any other questions.

Sincerely,
/s/ Brad Skinner

Show Raw Text
January 9, 2013

Via E -Mail
Mr. James Rozon
Chief Financial Officer
Gran Tierra Energy Inc.
300, 625 11 th Avenue SW
Calgary, Alberta
Canada T2R 0E1

Re: Gran Tierra Energy Inc.
 Form 10-K for Fiscal Year Ended December 31, 2011
Filed February 27, 2012
Response Letter Dated October 10, 2012
File No.  1-34018

Dear Mr. Rozon :

We have reviewed your response letter  and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the request ed
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2011

Proved Undeveloped Reserves, page 18

1. We note your response to comment one which indicates that you converted 3.9 MMBOE
of prove d undeveloped reserves and added 4.6 MMBOE of PUDs in Colombia.  Please
quantify the amount of investments to convert the 3.9 MMBOE and tell us how you
expect to comply with Item 1203 of Regulation S -K.

Mr. James Rozon
Gran  Tierra Energy Inc.
January 9, 2013
Page 2

 You may contact John Cannarella at (202) 551 -3337 if  you have questions regarding
comments on the financial statements and related matters.    Please contact me at (202) 551 -3489
with any other questions.

Sincerely,

        /s/ Brad Skinner

        Brad Skinner
        Senior Assistant Chief Accountant