SecProbe.io

November 15, 2005

Mail Stop 3561

via U.S. mail and facsimile

Christopher Yee
Samoyed Energy Corp.
10870 Harvest Lake Way NE
Calgary, Alberta
CANADA

Re:      Samoyed Energy Corp
Registration Statement on Form SB-2
Filed October 31, 2005
File No. 333-129331

Dear Mr. Yee:

We have limited our review of your filing to the issue we have addressed in our
comment.  Where indicated, we think you should revise your document in response to the
comment.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  After reviewing this info rmation, we may raise additional comments.

Please understand that the purpose of our re view 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 comment or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

General

1. We note that Samoyed Energy has not identified properties upon which it will conduct exploration activities.  For this reason, it does not appear that you have a
specific business plan within the meani ng of Rule 419 of Regulation C of the
Securities Act of 1933.  Please revise your registration statement and offering to
comply with Rule 419.

As appropriate, please amend your registration statement in response to this comment.
You may wish to provide us with marked copies of the amendm ent to expedite our

Christopher Yee
Samoyed Energy Corp.
November 15, 2005 Page 2

review.  Please furnish a cover letter with  your amendment that keys your responses to
our comment and provides any requested info rmation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendment a nd response to our comment.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the fili ng includes all information required under the
Securities Act of 1933 and that they have pr ovided 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 statem ent, it should furnish a letter, at the time
of such request, acknowledging that:

  should the Commission or the staff, ac ting pursuant to delegated authority,
declare the filing effective, it does not for eclose 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 effectiv e, does not relieve the compa ny from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

  the company may not assert staff comment s 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 advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision 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 th e fact that those requesting acc eleration are aware of their
respective responsibilities unde r the Securities Act of 1933 a nd the Securities Exchange
Act of 1934 as they relate to the proposed public  offering of the securi ties 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

Christopher Yee
Samoyed Energy Corp.
November 15, 2005 Page 3

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 Susann Reilly at 202-551-3236 if you have any questions.

     S i n c e r e l y ,

     John Reynolds,
Assistant Director
Office of Emerging Growth Companies

cc:  W. Scott Lawler, Esq.
       By facsimile at 951-506-8877