SecProbe.io

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Mail Stop 3561
      August 22, 2005

Chet Kurzawski
President
Hurley Exploration Inc.
1600 Golf Road, Suite 1200
Rolling Meadows, IL 60008

      Re:	Hurley Exploration Inc.
      Registration Statement on Form SB-2
      Filed July 26, 2005
		File No. 333-126900

Dear Mr. Kurzawski:

      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
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Summary, page 4
1. We note that on page 13 of the prospectus you state that if
developments warrant it, you will proceed with commercial
production.
Please expand you summary to include this fact.

Risk Factors, page 2
2. In general, descriptions of risks that describe circumstances
that
could apply equally to other businesses that are similarly
situated
are generic risks that should not be included in your risk factor
section.  Please either eliminate these generic risks, or revise
them
to state specific material risks to your company or to the
purchasers
in this offering.  For example, we note that the following risk
factors appear to contain generic disclosures:

* The production of minerals... page 5
* Our revenues are dependent... page 5
* No dividends and none anticipated, page 8

Please note these are examples only.  Review your entire risk
factor
section and revise as necessary.

Management`s Discussion and Analysis, page 10
3. We note that in your risk factors you state that your ability
to
execute your growth strategy depends on acquiring suitable
companies.
However, we do not see a discussion in your disclosure of your
business concerning acquiring other companies or entities.  Please
revise or advise.
4.  We note in your risk factors that you state that if you find
copper you may not be able to develop and market it and if you do
not
find copper you will cease operations.  Please revise your
disclosure
of your business to describe what you will do if you cease
operations
or you are unable to develop and market the copper you find.
5. Revise your filing to include a detailed liquidity plan.  In
this
regard your projected twelve month expenses exceed the amount of
cash
you have on hand.  See Item 303 of Regulation S-B.

Description of Business, page 11
6. Revise your filing to disclose whether the agreements with
Richard
Simpson to acquire a 100% interest in the two DON claims were
negotiated at arms length.
Management, page 22
7. In accordance with of Item 401 of Regulation S-B, please
provide
the last 5 years of business experience for Messrs. Kurzawski and
Reid.

Selling Stockholder, page 27
8. Please disclose the natural person(s) or public company that
has
the ultimate voting or investment control over the shares held by
GC
Consultants.
Plan of Distribution, page 29
9. We note your disclosure regarding short sales.  Please be
advised
that short sales of common stock "against the box" that are
covered
with shares subject to this registration statement cannot be made
before the registration statement becomes effective.  It is our
view
that shares underlying the short sale are deemed to be sold at the
time such sale is made and, prior to effectiveness, this would
constitute a violation of section 5.  Please confirm your
understanding.
10. Please revise your disclosure here to clarify that, to be
quoted
on the OTC Bulletin Board, a market maker must file an application
on
your behalf in order to make a market for your common stock.
Clarify
how long this takes and whether you have engaged a market maker to
apply for quotation on the OTC Bulletin Board on your behalf.
Explain what effect quotation on the OTC Bulletin Board will have
on
your liquidity.

Balance Sheet, page F-2
11. Please revise your Stockholders` Equity section of your
balance
sheet to sum properly.  In this regard, your statement does not
balance.

Statement of Operations, page F-3
12. Please revise your statement to reflect the fact that you had
an
operating loss, not income.  Furthermore, please revise your
statement to include a separate line for net loss.

Statement of Stockholders Equity, page F-4
13. Please revise your statement to ensure that your common stock
issued for cash sums across to agree to total equity reported.

Note 4 Mineral Properties, page F-9
14. Please explain to us how you determined it was appropriate
under
generally accepted accounting principles to expense your
investment
in the mineral properties you reference.  See paragraph 10 of SFAS
no. 7.
15. Please enhance your note disclosure to reflect the fact that
your
properties do not contain proven mineral reserves.  If the
property
you reference is without known reserves, a statement to that
effect
shall be made.  See Item 801 of Regulation S-K.

Note 5 Income Taxes, page F-10
16. Please revise your disclosure to include the dollar amount of
deferred tax asset you reference related to the loss carry-
forwards.
Also, state that you have fully reserved this deferred tax asset.
See paragraph 43 of SFAS no. 109.
Signature, page II-7
17. Please amend your filing to include your controller/principal
accounting officer`s signature.

*****

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies 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 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 filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment 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.

      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 staff comments and the declaration
of
effectiveness as a 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 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.

      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.

      You may contact Robert Babula, Staff Accountant, at (202)
551-
3339 or Mike Moran, Accounting Branch Chief, at (202) 551-3841 if
you
have questions regarding comments on the financial statements and
related matters.  Please contact Scott Anderegg, Staff Attorney,
at
(202) 551-3342 or me at (202) 551-3720 with any other questions.

      					Sincerely,

      					H. Christopher Owings
      Assistant Director

cc: 	Gregg E. Jaclin
	Anslow & Jaclin, LLP
      Via Fax (732) 577-1188

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Chet Kurzawski
Hurley Exploration Inc.
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