SecProbe.io

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October 14, 2004

via U.S. mail							via facsimile

Mr. David Zaikin						Mr. David Love, Esq.
Chairman & Chief Executive Officer			(713) 524-4122
Siberian Energy Group Inc.
275 Madison Ave., 6th Floor
New York, NY 10016

Re:	Siberian Energy Group Inc.
	Form SB-2 filed September 10, 2004
	File No. 333-118902

Dear Mr. Zaikin:

	We have reviewed 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
atthe end of this letter.

Form SB-2

General

1. Many of our comments apply to disclosure that appears in more than
one place.  To eliminate the need for us to issue repetitive
comments, please make corresponding changes to all affected
disclosure, wherever it appears in your document.

2. Prior to printing and distribution of the preliminary prospectus,
please provide us with copies of all artwork and any graphics you
wish to include in the prospectus.  Also provide accompanying
captions, if any.  We may have comments after reviewing these
materials.

3. At times, your disclosure appears inconsistent with the status of
your current business operations.  As appropriate, please revise to
include necessary context, including an emphasis on your lack of an
operating history and failure to generate any operating revenues
since inception.  For example, you refer to your "mineral
properties," you state you are "engaged in the acquisition and
exploration of mining properties" and you indicate you are
"commencing the research and exploration stage of our mining
operations."  However, it appears you have rights related to only one
property and that you are not engaged in the acquisition or
exploration of any properties.  Your registration statement should
provide a fair and complete picture of your business, including
balanced and accurate disclosure.

In this regard, we note that your licenses are only for 5 years and
can be renewed for 25 years but only if you discover hydrocarbons
(page 28).  You should include a risk factor to this effect and
revise your disclosure throughout your filing to address the impact
if you do not find hydrocarbons within that 5 year period.

4. We did not find disclosure fully responsive to Item 5 of Form SB-
2.  Please revise to ensure that you have complied with the
requirements of Item 5 of Form SB-2. We may have additional comments.

5. For your calculation of registration fee table, label those
numbers that correspond to the footnotes.

Prospectus Cover Page

6. We note that you currently lack a market for the company`s common
stock.  Consequently, disclose on the cover page of the prospectus
that the selling shareholders will sell at a price of $x.xx per share
until your shares are quoted on the OTC Bulletin Board and thereafter
at prevailing market prices or privately negotiated prices.

Please confirm that if you want to sell the securities at a price
that is different from the price that appears in your final
prospectus, you will file a post-effective amendment beforehand.
Note that you are not eligible to conduct an "at the market
offering."  See Rule 415(a)(4).

In this regard, the staff deems the offering of shares by Victor
Repin and Zaural Neftegaz to constitute a primary offering by the
company.  We note that those parties are control persons of the
issuer.  See the last sentence of Section 2(11) of the Securities Act
of 1933.  Even after listing on the OTCBB, sales by those parties
would constitute a primary offering.  Any change in price would
require the filing of a post-effective amendment.

7. Revise the last two paragraphs to remove the "all caps"
presentation.

Prospectus Summary, page 5

8. Tell us what affiliation, if any, existed between the company and
ZNG prior to the issuance of shares in May 2003.

Risk Factors, page 7

9. Eliminate language that tends to mitigate the risk you discuss.
Examples of this are statements such as "we hope that we will have
revenues" or "while this is not out of the ordinary."

10. Revise the risk factor subheadings to identify the risk and
potential harm concisely. Several captions merely state facts and
fail to describe the risk that follows, including without limitation,
"We lack a market for our common stock," "We lack profits from
operations" and "We lack an operating history which you can use to
evaluate us."

We lack an operating history..., page 7

11. Disclose the total amount of losses to date.

We lack profits from operations, page 8

12. Delete the second sentence as it mitigates the risk you are
discussing.  In this regard, until your exploration activities
confirm that you have proved reserves, it is inappropriate for you to
make such statements such as that you "plan to begin production in
2005."

Our business is speculative and risky, page 8

13. Delete the second sentence as it mitigates the risk you are
discussing.

Our industry is competitive..., page 8

14. Reconcile the discrepancy between the discussion in this section
that there are low barriers to entry into the oil and gas industry
and that on page 27 which discusses certain barriers to entry that
provide "a great deal of insulation for players."

We rely upon key personnel..., page 9

15. Please disclose if any of your "key personnel" are not under
contract and discuss specifically which personnel upon which you rely
and why.  If you do not have "key man" insurance for these
individuals, so indicate.

Special Note Regarding Forward-Looking Statements, page 10

16. As your risk factors section makes clear, your stock is subject
to the penny stock rules.  Therefore, the safe harbor that the PSLRA
of 1995 otherwise would provide is unavailable.  Ensure that all your
filings and company statements, including press releases, do not
refer to the safe harbor or otherwise suggest it is applicable.

Employment Agreements, page 13

17. Move this discussion to the section entitled "Executive
Compensation."

Security Ownership of Certain Beneficial Owners and Management, page
17

18. Add a reference to footnote (2) in the row for Zaural Neftegaz.

Description of Business

	General

19. We note that all activities related to the Company`s previous
business ventures were essentially discontinued prior to January 1,
2000.  Briefly discuss why this occurred and the current status of
these ventures or cross-reference to where these issues are
discussed.

History, page 18

20. Expand this section to explain why the company changed its name
to Talking Cards, Oysterking and 17388; and clarify whether
management and control of the company changed also.

21. In the fourth paragraph on page 19, identify the oil and gas
licenses rather than use the vague term "certain" or provide a cross-
reference to where greater description of those licenses is located.

22. Explain in more detail the creation of, and transaction with,
Siberian Energy (Canada). What was the business purpose of creating
the subsidiary?  Explain what you mean by the term "capital
subsidiary" and how it came to have a book value of $7.00.

The Parent - Siberian Energy Group Inc....page 20

23. Identify the other company that holds exploration licenses in
Kurgan Oblast.

24. Delete the second paragraph as it has no bearing on whether the
properties for which you have licenses will contain proved reserves.

History of Industrial Development in Russia, page 20

25. Describe for us the "additional industries" Kurgan is seeking to
develop and the relevance of that to the success of your operations.

Market Size and Share, page 25

26. Provide us with objective support for your statement that you
"have the commitment of the local government" or delete that
statement.

Financing Strategy, page 26

27. Disclose the time frame of the three stages you plan to use to
finance your projects.

28. Quantify the amount of funds you will need to complete each of
the three stages.

Alliance and Partnering Strategy, page 26

29. Explain what you mean by the phrase "leverage key relationships."

Exploration and Production Strategy, page 27

30. Explain in more detail what you mean by "an element of risk
sharing" and provide examples of how that would work.

Marketing Strategy, page 27

31. Since you have not yet even begun exploration to determine if
your properties contain hydrocarbons, it is premature to be
discussing marketing of production.  Revise this section to make it
clear that these activities could only occur if you discover
hydrocarbons within your license period and are able to successfully
extract those quantities and that there is no assurance that you will
do so.

Competition, page 27

32. In the second sentence, replace "upon proving hydrocarbons" with
"if hydrocarbons are found."

33. As you are in the early stages, it is unclear what you mean by
"the Company`s multi-year history in the province as well as its
large concessions provides [it] with a strong leadership position."
Please advise or revise.

34. You describe your competitors as "a very large number of junior
players."  Explain what you mean by the term "junior players."  Are
you in that category?  Also, are there any large corporations seeking
to establish operations in this area?

Costs and Effects of Compliance with Environmental Laws, page 28

35. Disclose the actual costs associated with complying with all
applicable laws and regulations, such as the cost to acquire your
exploration licenses.

Management`s Discussion and Analysis..., page 29

	Overview, page 29

36. Delete the second sentence.  There is no assurance that you will
be successful in discovering hydrocarbons and, even if you do, that
you will be able to extract it at price and cost levels resulting in
"significant profits" for your shareholders.

37. Please describe any known trends or uncertainties that you have
had or reasonably expect will have a material favorable or
unfavorable impact on short-term or long-term liquidity.

38. It is not clear in the third paragraph how your strategy will
result in "forcing ZNG`s efforts and resources."  Revise or delete
that statement.  Also, delete the statement that accelerated
development will "generate revenues earlier."  There is no assurance
that price and cost levels will generate such revenues.  Part 3 of
that paragraph is unclear.  Provide support for that statement or
delete that phrase.

Estimate of the Amount Spent During Each of the Last Two Fiscal Years
on Research and Development, page 30

39. Tell us what you mean by "time market research."

Liquidity and Capital Resources, page 31

40. We note that for the six months ended June 30, 2004, the Company
received $34,426 in additional paid-in capital.  Disclose where this
additional capital arose.

41. Provide greater detail as to why there is at least a 50% chance
that your tax net operating loss carryforwards as of December 31,
2003 will expire unused.

Description of Property, page 32

42. Disclose from whom your properties are leased, and advise whether
the properties are used by any others or for any other purpose.

Executive Compensation, page 34

43. Please include those executives listed in the table on page 11 in
the table in this section to ensure full compliance with Item 402 of
Regulation S-B.

Plan of Distribution and Selling Stockholders, page 37

44. Please tell us whether any of the selling stockholders are a
broker-dealer or an affiliate of a broker-dealer.

45. Identify any selling shareholders who have had any position,
office or other relationship with the company, its predecessors or
affiliates.  We note, for instance, that Victor Repin and Zaural
Neftegaz are among the selling shareholders.  See Item 507 of
Regulation S-B.

46. Identify the beneficial owner of the shares held by Zaural
Neftegaz.

47. Clarify how and when the selling shareholders acquired their
shares.  We note the disclosure under Item 26 but are unable to
reconcile that information with the table on page 37.

Signatures

48. It appears that not all of the required signatures are present.
Ensure that you have complied with the Instructions for Signatures on
Form SB-2.

Engineering Comments

Risk Factors, page 7

49. Expand your risk factor discussion to include the requirement
that 70% of your production must be sold to the domestic Russian
market and that you have no experience in dealing with major oil
service companies, e.g. Schlumberger, Halliburton, BJ Services etc.

Our Business is Speculative and Risky, page 8

50. Here you state, "We hope that since our operating fields are part
of the western Siberia Basin in Russia, one of the world`s richest
resource regions, the probability of finding hydrocarbon deposits is
relatively high".  Delete this statement as it mitigates your
presentation of risk.

The Subsidiary - Zaural Neftegaz, page 20

51. Amend your document to explain that Russia`s overall rank among
world oil producers does not necessarily mean that you will be
successful in oil and gas exploration and production.

52. Delete your statement, "The Kurgan region was not assigned to oil
production and as a result, the area has many untapped oil and gas
resources." as it is unsupported by technical information.

Geography, page 21

53. Amend your statement, "The blocks that ZNG owns are located..."
to disclose that you have only extractive rights here.

54. Amend your narrative here about the surrounding regions to
disclose the fact that this gives no evidence that your future
operations in the Kurgan Oblast will be successful.

55. Here you state, "This area [Kurgan] has been surveyed by the
Russian Ministry of Geology, which has determined that this area has
commercial prospects for the production of oil, gas and other
petroleum products".  Amend you document to support this statement
with technical information or delete it.  Address whether the
Ministry made this determination specifically for each of your four
license areas.  Supplementally submit to us the pertinent engineering
and geological information that supports this statement.

Exploration Rights - Testing and Study, pages 22-23

56. Here and elsewhere you use technical terms that are not familiar
to the public.  Amend your document to define/explain such terms as
initial arrival method (IAM), depth point measuring method (DPMM),
abyssal entry method (AEM), abyssal seismic entry method (ASEM),
parametric drilling, gravitational, magnetic and aerospace surveys,
thermal, radiant, vapour-chromotography, microbiologic oil geology
methods, geo-dynamic and local tectonic testing.  Include the
"fifteen different methods" of the Institute of Oil and Gas Geology
on page 25.  Consider including a glossary for these and other
technical terms.

57. Here you state, "ZNG has reviewed the government-supplied
geographical [sic] data relating to the Exploration Rights and is
currently at the seismic survey stage.  Currently, all four blocks
covered by the Exploration Rights are being evaluated and explored".
Amend this to explain the individual methods you are using to
evaluate and explore these license areas.  Be advised we do not
consider seismic data to be sufficient for the attribution of proved
reserves.

58. Amend