SecProbe.io

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                         DAVID M. LOEV, ATTORNEY AT LAW
                         2777 ALLEN PARKWAY, SUITE 1000
                                HOUSTON, TX 77019
                            TELEPHONE (713) 524-4110
                            FACSIMILE (713) 524-4122

                               January 25, 2005

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. FORM SB-2 SUPPLEMENTAL DRAFT RESPONSE FILED
JANUARY  5,  2005,  FILE  NO.  333-118902

Dear  Mr.  Wynn:

In  response  to  your letter dated January 19, 2005, Siberian Energy Group Inc.
(the  "Company")  has  the  following  responses:

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

     1.     We  recognize  the  confusion  associated  with  the use of the word
"suggested"  as  it  was  originally  used.  We did not mean to suggest that the
Ministry physically contacted the Company and suggested the licenses.  We merely
wanted  to  say  that the Ministry followed common license-issuing procedure and
issued the licenses.  Therefore, we have revised the word "suggested" as used in
previous  drafts  of  the  Company's  SB-2,  to more specific detailed language:
     "The  Ministry  identified  and parceled eight  potential  areas  that  may
contain hydrocarbon reserves, and issued  eight  licenses for those areas,  four
of  which are held by ZNG.  The allocation of the licensed areas by the Ministry
was  based  primarily  on  existing  geological  land  studies  and  preliminary
geologists'  forecasts  of hydrocarbon potential, aggregated in official reports
and  prepared  on  behalf  of  geological institutions in Tyumen and Novosibirsk
regions.  The  allocation  of  these eight areas was based primarily on existing
geological  land  studies  and  preliminary  geologist  forecasts.  There  is no
guarantee  however  that  ZNG's blocks hold any oil or that if ZNG finds oil, it
will  be  in  commercial  quantities."

DRILLING  ACTIVITIES  IN  THE  REGION
-------------------------------------

     2.     We  have  revised this section to clearly state that traces of heavy
hydrocarbon  deposits  and  gas  eruptions  are  not  prima  facie  evidence  of
commercial  deposits,  and  added  the  following  language:
     "Traces  of  heavy  hydrocarbons  and gas eruptions were detected at depths
less  then  1200m;  however,  these  traces  are  not  prima  facie  evidence of
commercial deposits.  Two of the 12 wells drilled in the 1980s have been drilled
on  the  territory of the licensed areas covered by ZNG, one in the West-Suersky
block  and  one  in  the  Privolny  block.  No  heavy hydrocarbons were detected
immediately on the blocks, except for gas eruptions detected from a well drilled
on  the  Privolny  block,  which  is  not  prima  facie  evidence  of commercial
deposits."

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FINANCING  STRATEGY
-------------------

     3.     We have added a section of the SB-2 entitled "Geological Experts" to
better  disclose  the  Company's  three experts: Alexander V. Rilkov, Nikolay P.
Zapivalov,  and Andrey U. Belonosov, as well as adding consents from these three
individuals  to  be named as experts in the SB-2.  The consents will be attached
as  exhibits  23.3,  23.4,  and  23.5  to  the  amended  SB-2.

ALLIANCE  AND  PARTNERING  STRATEGY
-----------------------------------

     4.     We have provided greater detail to why dealing with one partner over
many  may  be  advantageous  for  the  Company.

     We  have  added  the  following language to the SB-2: "The Company believes
that  one  partner  would  be  advantageous  to the Company because: (i) a large
partner  can  contribute  professional  management  expertise,  by  planning,
executing, and monitoring ZNG's operations; (ii) dealing with one major investor
can  offer  better  terms  of  trade  in  terms  of  exchange  of  ownership for
investment;  (iii)  the  Company  believes  that  large organizations offer more
stable  investments  and  longer  term  partnerships;  (iv)  if the organization
carries  a history, size, market knowledge and reputation, these factors may add
significant  credibility  to  both  partners;  (v)  the Company believes that an
investing  entity which enters into a relationship with the Company as a partner
is  more  inclined  to have the capacity to meet short and long-term obligations
with  the Company if obligations are shared by both the Company and the partner;
and  (vi)  to  enter  into risk-sharing arrangements. While the Company believes
that  there  are  several advantages to dealing with a single partnering entity,
the  Company  is  not  exclusively  targeting only large investors or partners."

SUBSEQUENT  EVENTS
------------------

     5.     We  will  file  the  Company's  consulting  agreement  with  Aspen
Management  Inc.  as  exhibit  10.25  to  the  amended  SB-2.

ENGINEERING  COMMENTS
---------------------

     6.     We have removed all mention of increasing Russian oil and gas prices
from  the  amended  SB-2.

Very  truly  yours,

/S/  DAVID  M.  LOEV

DAVID  M.  LOEV,  ATTORNEY  AT  LAW

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