SecProbe.io

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                                  DAVID M. LOEV
                                 ATTORNEY AT LAW
                         2777 ALLEN PARKWAY, SUITE 1000
                              HOUSTON, TEXAS 77019
                             (713) 524-4110 - PHONE
                              (713) 524-4122 - FAX

November  23, 2004

Mr. Jason Wynn
Division of Corporate Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

RE:     Siberian Energy Group Inc. File No 333-118902

Dear Mr. Wynn:

We  have  enclosed  three red-lined copies of the amended registration statement
for  your  review.   In response to your letter dated October 14, 2004, Siberian
Energy  Group  Inc.  (the  "Company")  has  the  following  responses:

GENERAL
-------

1.   We  have  made  the  changes  you have asked for in your letter, as well as
     making  the  corresponding  changes  throughout  the Registration Statement
     where  applicable.

2.   We  do  not  have any artwork or graphics to be included in the prospectus.

3.   We  have  revised  the Registration Statement to include an emphasis on our
     lack of operating history and added an additional risk factor regarding the
     potential  that  the  Company's  licenses  will  not be extended past their
     initial  5-year  terms.

4.   We  have  revised  the  calculation  of the registration fee table to fully
     comply  with  Item  5  of  Form  SB-2  including adding disclosure that the
     Company's  stock  is  not  quoted  on  any  public  markets.

5.   We  have  added footnotes corresponding to the headings in the registration
     fee  table.

<PAGE>

PROSPECTUS  COVER  PAGE
-----------------------

6.   We  have  added  language regarding the fact that selling shareholders will
     sell  at  a  fixed  price  of  $0.10 until the shares are quoted on the OTC
     Bulletin Board, as well as the fact that we currently lack a market for the
     company's  common  stock.  Additionally,  we have added language confirming
     that  if the securities are to be sold at a different price from that which
     appears  in  the  final prospectus, we will file a post-effective amendment
     beforehand.  In  regards  to  your  comments  concerning  the  offering
     constituting  a "primary offering," we have removed Victor Repin and Zaural
     Neftegaz  ("ZNG")  as  selling  shareholders.

7.   We  have  revised  the  last two paragraphs of the Prospectus Cover Page to
     remove  the  "all  caps"  presentation.

PROSPECTUS  SUMMARY
-------------------

8.   We  have  added  information  to  disclose  the  fact  that  there  was  no
     affiliation  between ZNG and the Registrant prior to the issuance of shares
     in  May  2003.

RISK  FACTORS
-------------

9.   We  have  eliminated  language throughout the "Risk Factors" section, which
     tends  to  mitigate  the  risks  regarding  the Company and its securities.

10.  We  have  revised  the  subheadings  under  "Risk Factors," to more clearly
     identify  the  risks  and  potential  harms  associated  with  each  risk.

     We  lack  an  operating  history
     --------------------------------

11.  We  have  disclosed  the total amount of losses the Company has incurred to
     date.

     We  lack  profits from  operations
     ----------------------------------

12.  We  have  deleted  the  second  sentence  of this risk and have revised the
     entire risk factor to remove inappropriate statements concerning the future
     of  the  Company.

     Our  business is  speculative  and  risky
     -----------------------------------------

13.  We  have  deleted  the  second  sentence  of  the  risk  factor.

     Our  industry  is  competitive
     ---------------------------------

14.  We  have  deleted and revised the language of this risk factor to reconcile
     the  earlier  discrepancy  with  language  found  later in the Registration
     Statement  regarding  the  competitiveness  and  barriers  to  entry of the
     Company's  industry.

<PAGE>

     We  rely  upon  key  personnel
     ---------------------------------

15.  We  have  disclosed  which "key personnel" are under contract and discussed
     which  personnel  we rely and why. Additionally we have added disclosure of
     the fact that we hold no "key man" insurance on any of those key personnel.

SPECIAL  NOTE  REGARDING  FORWARD-LOOKING  STATEMENTS
-----------------------------------------------------

16...We have ensured that all of the Company's filings and statements, including
     press  releases  have  not referred to the safe harbor or otherwise suggest
     that  it is applicable in this Registration Statement. We have also removed
     the  section  we  had  previously  explaining "forward looking statements."

EMPLOYMENT  AGREEMENTS
----------------------

17.  We  have  moved  the  "Employment  Agreement"  discussion to the "Executive
     Compensation"  section  as  you  requested.

SECURITY  OWNERSHIP  OF  CERTAIN  BENEFICIAL  OWNERS  AND  MANAGEMENT
---------------------------------------------------------------------

18.  We  have  added a reference to footnote (2) in the row for Zaural Neftegaz.

DESCRIPTION  OF  BUSINESS
-------------------------

     General
     -------

19.  We have added a discussion of the Company's previous business ventures, the
     reason  for  the  Company's  change  in business focus, the reason for each
     change  in  the  Company's  name  and  the  current status of the Company's
     previous  business  ventures.

     History
     -------

20.  We  have  expanded  this section to explain why the Company had changed its
     name to Talking Cards, Oysterking and #17388, as well as clarifying whether
     management  and  control  of  the  Company  changed  as  well.

21.  We  have  identified  the  four (4) specific oil and gas leases rather then
     referring  to  them  generically  as  "certain  leases."

22.  We  have explained in greater detail the creation of, transaction with, and
     purpose  of creating Siberian Energy (Canada) as well as specifying how its
     valuation  was  calculated.

<PAGE>

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

23.  We  have  identified  the  other company that holds exploration licenses in
     Kurgan  Oblast  as  you  requested.

24.  We  have  deleted  the  second  paragraph of this section as you requested.

     History  of  Industrial  Development  in  Russia
     ------------------------------------------------

25.  We  have described the "additional industries" Kurgan is seeking to develop
     as  well  as  the relevance of those industries to the potential success of
     our  operations.

     Market  Size  and  Share
     ------------------------

26.  We  have  deleted  the  statement regarding the Company's commitment of the
     local  government.

     Financing  Strategy
     -------------------

     27.  We  have disclosed the time frame and methods that we expect to use to
          finance  our  projects.

     28.  We  have quantified the amount of funds we will require for completion
          of  each  of  the  future  projects  detailed  in  question  27.

     Alliance and  Partnering  Strategy
     ----------------------------------

29.  We  have  explained  what  was  meant  by  the  phrase  "leverage  key
     relationships."

     Exploration and  Production  Strategy
     -------------------------------------

30.  We  have explained in greater detail what we meant in the previous draft by
     "risk  sharing" and provided examples of how the Company believes the "risk
     sharing"  will  work.

     Marketing  Strategy
     -------------------

31.  We  have  revised  this  section  to  make  it  clearer  that the marketing
     activities  discussed  will  take  place  only  if  the  Company  discovers
     hydrocarbons  within  the  5-year  licensing  period.

<PAGE>

     Competition
     -----------

32.  We  have  deleted  the section to which your original question 32 referred.
     However,  we  have  updated  language throughout the Registration Statement
     which  mitigated  the  risk that we will not find any hydrocarbon reserves.

33.  We  have  revised this section to explain previous statements regarding the
     "Company's  multi-year  history in the province." The Company feels that by
     the  time  the new parcels become available for distribution in the region,
     the  Company  will  have an advantage over their competitors because of the
     experience  they  have  gained  up  until  that  point.

34.  We have described in greater detail was meant by the term, "junior players"
     and have added information regarding large corporations who are competitors
     of the Company. Additionally, we have added disclosure of the fact that the
     Company  is  a  "junior  player."

     Costs  and  Effects  of  Compliance  with  Environmental  Laws
     --------------------------------------------------------------

35.  We have disclosed the actual costs associated with the Company's compliance
     with  applicable  laws  and  regulations.

MANAGEMENT'S  DISCUSSION  AND  ANALYSIS
---------------------------------------

     Overview
     --------

36.  We  have  deleted  the  second  sentence  of this section as you requested.

37.  We  have  described known trends and uncertainties that the Company expects
     will  have  a  material  favorable  and unfavorable impact on the Company's
     short-term  and  long-term  liquidity.

38.  We  have  revised  the  third  paragraph  of  this  section,  deleting  the
     statements  you  requested  regarding  "forcing  [of]  ZNG's  efforts  and
     resources"  and  revising the other statements to make the Company's future
     plans  more  clear.

     Estimate  of  the  Amount Spent During Each of the Last Two Fiscal Years on
     ---------------------------------------------------------------------------
     Research  and  Development
     ------------------------

39.  We have clarified the use of the term, "time market research." The sentence
     was  intended  to  read,  "during  which  time,  market  research  was
                                               -----------------------
     conducted"  not  "time  market  research,"  and  we  have  clarified.
                       -----------------------

<PAGE>

     Liquidity  and  Capital  Resources
     ----------------------------------

40.  We have explained in greater detail where the $34,426 of additional paid in
     capital  came  from.

41.  We  have  provided greater detail as to why the Company believes that there
     is  a  50%  chance  that  its  tax  net  operating loss carryforwards as of
     December  31,  2003  will  expire.

DESCRIPTION  OF  PROPERTY
-------------------------

42.  We  have  disclosed  from  whom  our properties are leased and explained in
     greater  detail the other purposes that our leased properties are used for.

EXECUTIVE  COMPENSATION
-----------------------

43.  We  have  added  the  salary information for Elena Pochapski, the Company's
     Chief  Financial  Officer.

     Additionally,  we have added salary information on Bruna Compagnoni who was
     the  Company's  president  previous  to Shakeel Adams, and falls within the
     three  fiscal  year  reporting  period  of  Item  402  of  Regulation  S-B.

     However,  we  believe  that  there is no disclosure required for any of the
     Company's  other  executives  because  their annual salaries fall below the
     $100,000.00 minimum floor of Item 402 (Instruction 1) when including salary
     and  bonuses.

     Oleg  Zhuravlev received a $32,000 salary from the Company in 2003 and will
     receive  the  same salary for 2004. Mr. Zhuravlev also holds stock options.
     However,  none  of  his  options  have been exercised. Therefore, his total
     compensation  for the fiscal year ending 2003 would be only $32,000 and his
     total  salary  for  2004  would  be  $32,000,  both  of which are under the
     $100,000.00  minimum,  required for disclosure of executives other then the
     Chief  Executive  Officer  of  the  Company.

     Sergey  Potapov  and  Valdimir Eret both receive salaries of $30,000.00 per
     year  and stock options from the Company. Mr. Potapov and Mr. Eret have not
     exercised  any  of  their stock options to date. Therefore, we believe that
     both  fall  below  the  $100,000.00  minimum  annual salary requirement for
     disclosure  under  Item  402.

     Additionally,  we have added disclosure of the fact that no other executive
     employees  have been paid more then $100,000.00 in consideration, including
     bonuses  and  options,  over  the  Company's  last  three  fiscal  years.

<PAGE>

PLAN  OF  DISTRIBUTION  AND  SELLING  SHAREHOLDERS
--------------------------------------------------

44.  We  have  disclosed  the  fact  that  none  of the selling stockholders are
     broker-dealers  or  affiliates  of  broker-dealers.

45.  We  have  removed  both  Victor  Repin and Zaural Neftegaz from the list of
     selling  shareholders.  Additionally,  we added a section below the list of
     selling  shareholders,  "Relationships  of  Selling  Shareholders,"  which
     identifies  any  selling  shareholders who have had any position, office or
     other  relationship  with  the  Company,  its  predecessors  or affiliates.

46.  We  have  removed  Zaural  Neftegaz  as  a  selling  shareholder.

47.  We have added information on how and when the selling shareholders acquired
     their  shares. We were unable to obtain information on the compensation and
     date acquired for all of the selling shareholders however, because many had
     received  their  shares  before  the Company's current management took over
     control  of  the  Company.

SIGNATURES
----------

48.  We  have  added  the  required  signatures  of  a  majority of the board of
     directors  of  the  Company.

ENGINEERING  COMMENTS

RISK  FACTORS
-------------

49.  We  have  added  a  risk  factor  that specifically discusses the Company's
     requirements  under Russia's export quotas titled "If We Do Produce Oil, We
     Must  Sell  70% of Our Oil Production in the Domestic Russian Market, Which
     Will  Mean  that  We Will Only Be Able to Sell 30% Of Our Production In The
     More  Lucrative  Foreign  Markets." Additionally, we added information to a
     previous  risk  factor  discussing  the competitiveness of the industry and
     disclosing  the  fact  that  the  Company  has  less  experience then other
     competitors.

Our  Business  is  Speculative  and  Risky
------------------------------------------

50.  We have deleted statements in this section which mitigated the risks of the
     Company's  business.

<PAGE>

THE  SUBSIDIARY  -  ZAURAL  NEFTEGAZ
------------------------------------

51.  We  have  amended  this section to explain that simply because Russia ranks
     high  among  the  worlds oil producers it does not in any way mean that the
     Company  will  be successful in its oil and gas exploration and production.

52.  We  have  deleted the statement, "The Kurgan region was not assigned to oil
     production  and  as  a  result,  the  area  has  many  untapped oil and gas
     resources,"  as  you  requested.

GEOGRAPHY
---------

53.  We  have  amended the statement, "The blocks that ZNG owns are located " to
                                                           ---
     "The  blocks  that  ZNG  holds  the  exploration  rights  to  are located "
                              -------------------------------

54.  We  have  added  disclosure  of  the  fact  that  even though the area that
     surrounds  the Company's blocks may contain