SecProbe.io

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December 21, 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 November 23, 2004, as amended
      	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
at the end of this letter.

      Form SB-2

Risk Factors, page 7

Our drilling licenses may not be renewed..., page 8

1. We note that the company acquired four exploration licenses on
March 7, 2003. Provide verification that these licenses are
renewable
after their initial five-year term expires.

Geography, page 20

2. You state that the "Ministry suggested eight potential areas
that
may contain hydrocarbon reserves...."  Please clarify what is
meant
by the word "suggested" as it is used in this context.

Description of Business

      Financing Strategy, page 23

3. We note that the company has enlisted the services of noted
geologists to review the preexisting geological data by the
Russian
government.  Disclose in further detail the actual services
provided
by the geologists, including the nature of the review, the final
results of that review and any actions that you took or plan to
take
according to those results.  On a supplemental basis, please
identify
these noted geologists and briefly explain their credentials.
Also,
provide us with a supplemental analysis as to whether the noted
geologists should (1) be identified as experts pursuant to Section
7(a) of the Securities Act and (2) file consents according to Item
601(b)(23) of Regulation S-B.  We may have further comments.

Alliance and Partnering Strategy, page 24

4. Explain further what is meant by the statement that "The
Company
would prefer that ZNG deal with one partner rather than many
private
investors."

5. Explain the nature of the term "farm-in agreements."

6. We note that the Company has entered into contractual
agreements
with two Russian companies to perform a gravimetric survey and
two-
dimensional seismic studies.  It appears that these contractual
agreements constitute material contracts not made in the ordinary
course of business.  Please explain to us why this is not the
case.
Otherwise, please file the contractual agreements as exhibits
pursuant to Item 601(b)(10) of Regulation S-B.  Please note that
if
you file any documents that are in a foreign language, that they
should be accompanied by a summary, version or translation in the
English language.  See Securities Act Rule 403(c).

Drilling Activities in the Region, page 21

7. Please expand this section to explain that "traces of heavy
hydrocarbons and gas eruptions" are not prima facie evidence of
commercial deposits.  Disclose whether the two wells drilled on
your
licensed blocks recovered hydrocarbon traces.

Glossary of Technical Terms Used in This Prospectus, page 28

8. The only definitions of proved oil and gas reserves that are
applicable to documents filed with the Commission are those in
Rule
4-10(a) of Regulation S-X.  Please amend your document here to
include only those definitions contained in Rule 4-10(a),
paragraphs
(2) through (2)iii, (3) and (4).  You may refer the reader to our
website, http://www.sec.gov/divisions/corpfin/forms/regsx.htm#gas.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 29

	Overview, page 30

9. Supplementally, support your beliefs that:

* "[there is a] tendency of Russian domestic oil and gas prices to
increase towards the worlds prices";

* "[there is an] increasing overall credit rating in Russia".

Closing Comments

      Please amend your registration statement in response to
these
comments.  You may wish to provide us with a marked copy of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested supplemental information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your amendment 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
for
an informed 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.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate 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 advance of the requested
effective date.

	Notwithstanding our comments, in the event 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 this action as 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 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 a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate 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
acceleration of the effective date.

      No other review of the registration statement has been made.
All persons who are by statute responsible for the adequacy and
accuracy of the registration statement are urged to be certain
that
all information required under the Securities Act of 1933 has been
included.  You are also reminded to consider applicable
requirements
regarding distribution of the preliminary prospectus.

      Please direct questions regarding accounting issues and
related
disclosures to John Weitzel at (202) 942-1807 or, in his absence,
to
Barry Stem, Senior Assistant Chief Accountant, at (202) 942-1919.
Direct all questions regarding engineering comments to Ron
Winfrey,
Oil and Gas Engineer, at (202) 942-1778.  Direct questions
relating
to all other disclosure issues to Jason Wynn, at (202) 824-5665
or,
in his absence, to the undersigned at (202) 942-1870.   Direct all
correspondence to the following ZIP code:  20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director

cc:	J. Weitzel
	B. Stem
      R. Winfrey
      J. Wynn
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Siberian Energy Group Inc.
December 21, 2004
page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

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