SecProbe.io

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January 19, 2005

via U.S. mail							via facsimile

Mr. David Zaikin							Mr. David Loev, 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
      	Supplemental Draft Response filed January 5, 2005
      	File No. 333-118902

Dear Mr. Zaikin:

      We have reviewed your supplemental draft response 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

Description of Business

	Geography, page 20

1. It still is not clear to us how the Ministry "suggested" these
areas.  Explain to us how this was done.

Drilling Activities in the Region, page 21

2. We cannot locate your response to the first sentence of prior
comment number 7.  Please expand this section to explain that
"traces
of heavy hydrocarbon deposits and gas eruptions" are not prima
facie
evidence of commercial deposits.

      Financing Strategy, page 23

3. We note your response to comment number 3 from our letter dated
December 21, 2004.  You state in the prospectus that "noted
geologists...have been enlisted in order to review the preexisting
geological data."  The expertise of these individuals is
highlighted
for investors and the act of reviewing data is an expertising
function.  The disclosure suggests that their review will have an
impact upon your financing strategy and which properties to
explore.
It is the staff`s position that these individuals constitute
experts.
Revise the filing to identify these individuals. Supplementally
provide us with consents from these persons to being named as
experts
in the prospectus.

Alliance and Partnership Strategy, page 24

4. We are unable to locate the "greater detail" you cite in your
response number 4.  Clarify how dealing with one partner rather
than
many private investors "would facilitate low upfront capital
investment on the part of the Company."   Please revise.

Subsequent Events, page 40

5. We note that the Company entered into a consulting agreement
with
Aspen Management Inc. on October 1, 2004.  It appears that this
contractual agreement constitutes a material contract not made in
the
ordinary course of business.  Please explain to us why this is not
the case.  Otherwise, please file the contractual agreement as an
exhibit 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).

Engineering Comments

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

	Overview, page 30

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

6. Your response 9 indicates that there is considerable opposition
to
increasing Russian domestic oil and gas prices to the world level.
Your graphic comparison of world oil prices and Urals 32 price
does
not offer any information about Russian domestic price history
since
the Urals 32 price you presented is for export.  Your statement
that
the Russian Federation government will increase the 2005 domestic
price for natural gas does not mean there will be other increases
later nor does it consider any increases in the world natural gas
price for 2005 and beyond.  Please delete this statement from your
document.

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.
January 19, 2005
page 1

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

         DIVISION OF
CORPORATION FINANCE

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