SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
   Mail Stop 7010

September 25, 2007

Via U.S. mail and facsimile

Mr. V. Bruce Thompson
Senior Vice President
SandRidge Energy, Inc.
1601 N.W. Expressway, Suite 1600
Oklahoma City, Oklahoma 73118

Re: SandRidge Energy, Inc.
 Amendment No. 2 to Registrati on Statement on Form S-1
Filed September 4, 2007
File No. 333-144004

Dear Mr. Thompson:

We have reviewed your filing and have the following comments.  We will
forward you in a separate lett er any additional engineering comments that we may have.
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.  Pl ease 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 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 comments or on 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 your response to our prior comment  2.  Further revise the disclosure you
have added on page 127 regarding the shelf resale registration statement to make
clear what constitute the “certain exceptions” to the lock-up provisions.

Mr. V. Bruce Thompson
SandRidge Energy, Inc
September 25, 2007 Page 2
2. We note your response to our prior comment 3 and reissue it.  Also make sure that
the contracts and other exhibits (such as exhibit 4.9) are filed in complete form,
including all annexes, etc.

Executive Compensation and Other Information

Setting Executive Compensation, page 98
3. You state that each June Mr. Ward review s and may adjust the compensation levels
of the executive officers, including his own compensation.  However, in  the
“Executive Compensation Changes in Fiscal 2007” section on page 103, you indicate that the Board was also involved  in the decisions setting the compensation
levels in June.  Please clarify the Board’ s role in setting co mpensation mid-year.

Related Party Transactions, page 118
4. We note your disclosure on page F-58 in  Note 15 to your Notes to Condensed
Consolidated Financial Statements (Una udited) for the period ended June 30, 2007
in regard to the transaction on May 2, 2007 involving the purchase of leasehold
acreage from a partnership controlled by a director for $8.3 million.  Disclose this
transaction in the related pa rty section, if required by Item 404 of Regulation S-K.

Other Transactions, page 118
5. We note your response to our prior comment  18.  With regard to Mr. Mitchell,
please make clear for each referenced tran saction (1) the terms and (2) whether you
are able to conclude that the transaction was on terms similar to those obtainable from third parties.  For example, identify each of the non-core assets sold to Mr. Mitchell, and state the price at which each as set was sold.  Also identify the wells in
which Mr. Mitchell owns a small working in terest.  Clarify whether a disinterested
majority of the Board and the stockholders  approved the sale of your interest in
Longfellow Ranch Partners to Mr. Mitchell.

Exhibit Index
6. Substantially revise the list of exhibits he re and in Item 16 to disclose precisely
when and with what filing the referenced exhibits were previously filed.  For example, you include only a single asteri sk to refer to all prior filings, and you
include no precise entry with respect to exhibit 24.1.

Mr. V. Bruce Thompson
SandRidge Energy, Inc
September 25, 2007 Page 3
Closing Comments

As appropriate, please amend your regist ration 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 cove r 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 amendmen t 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 in formation 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 ev ent 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 comment s and the declaration of effectiveness
as a defense in any proceeding initiat ed 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 conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te 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.

Mr. V. Bruce Thompson
SandRidge Energy, Inc
September 25, 2007 Page 4
We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate 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 a dvance of the requested effective date.

Please contact Lily Dang at (202) 551-3867 or, in her absence, Jennifer Gallagher,
at (202) 551-3706 if you have questions rega rding comments on the financial statements
and related matters.  Please contact Jame s Murphy, Petroleum Engineer, at (202) 551-
3703 if you have questions regarding comment s on the engineering matters.  Please
contact Donna Levy at (202) 551-3292 or, in her absence, Timothy Levenberg, Special
Counsel, at (202) 551-3707 with  any other questions.

       S i n c e r e l y ,

       H .  R o g e r  S c h w a l l
       A s s i s t a n t  D i r e c t o r

cc: T. Mark Kelly, Esq. (by facsimile)
L. Dang
 D. Levy
 T. Levenberg
J .  M u r p h y