SecProbe.io

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November 28, 2005

Mr. Scott Anderegg
Division of Corporation Finance
U.S. Securities & Exchange Commission
Mail Stop 3561
Washington, DC 20549

         Re:      Hurley Exploration Inc.
                  Amendment No. 1 to Registration Statement on Form SB-2
                  Filed November 11, 2005
                  File No. 333-126900

Dear Mr. Anderegg:

We  represent  Hurley  Exploration  Inc.  ("Hurley").  We are in receipt of your
letter dated  November 17, 2005  regarding the above  referenced  filing and the
following are our responses:

1.   We note your response to comment 3 in our letter dated August 22, 2005 and
     the revisions you have made in your Management's Discussion and Analysis.
     However, you still need to reconcile your risk factor discussion and
     Management's Discussion and Analysis discussion as it relates to your
     growth strategy. In your risk factor section you focus on acquiring
     suitable companies while your Management's Discussion and Analysis
     discusses acquiring suitable exploration properties. Please revise.

     Answer:   The SB-2 has been revised to reconcile the risk factor discussion
               and Management's Discussion and Analysis discussion as it relates
               to the Company's growth strategy to clarify that the Company will
               look to acquire suitable exploration properties.

2.   Please update your registration statement to include financial statements
     for the period ended September 30, 2005. See Item 310(g) of Regulation S-B.

     Answer:   The SB-2 has been updated to include financial statements for the
               period ended September 30, 2005.

Very truly yours,

ANSLOW & JACLIN, LLP

By: /s/ Gregg E. Jaclin
   --------------------
   GREGG E. JACLIN

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