SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628

DIVISION OF
CORPORATION FINANCE MAIL STOP 4628
        February 3, 2010

Mr. Robert “Steve” Owens
Chief Executive Officer Ring Energy, Inc. 18 ½ East State Street, Suite 202 Redlands, California  92373
 Re: Ring Energy, Inc.
  Form 10-K for the Fiscal Year Ended September 30, 2009
Filed December 29, 2009
  File No. 333-140024

 Dear Mr. Owens:
We have reviewed your filing and have the following comments.  We have
limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.  Please provide a written response to our comments.  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.

Form 10-K for Fiscal Year Ended September 30, 2009

Management’s Annual Report on Internal Controls over Financial Reporting, page 11

1. It does not appear that your management has performed its assessment of internal control over financial reporting as of September 30, 2009.  Since you were required to file or filed an annual report for the prior fiscal year, it appears you are required to report on your management’s assessment of internal control over financial reporting.

Mr. Robert “Steve” Owens
Ring Energy, Inc.
February 3, 2010 Page 2

  If your management has not yet performed its assessment, we ask that you
complete your evaluation and amend your filing within 30 calendar days to provide the required management's report on internal control over financial reporting.
  In performing your evaluation, you may find the following documents helpful:
ƒ the Commission’s release Amendments to Rules Regarding Management’s
Report on Internal Control Over Financial Reporting  (Securities Act Release
8809/Financial Reporting Release 76).  You can find this release at:
http://www.sec.gov/rules/final/2007/33-8809.pdf ;

ƒ the Commission’s release Commission Guidance Regarding Management’s
Report on Internal Control Over Financial Reporting Under Section 13(a) or
15(d) of the Securities Exchange Act of 1934 (Securities Act Release
8010/Financial Reporting Release 77).  You can find this release at
ƒ http://sec.gov/rules/interp/2007/33-8810.pdf ; and

ƒ the “Sarbanes-Oxley Section 404 – A Guide for Small Business” brochure at:
(http://www.sec.gov/info/smallbus/404guide.shtml ).

In addition, please consider whether management’s failure to perform or complete its report on internal control over financial reporting impacts its conclusions regarding the effectiveness of your disclosure controls and procedures as of the
end of the fiscal year  covered by the report and revise your disclosure as
appropriate.

Finally, we note that you filed your Principal Executive Officer and Principal Financial Officer certifications under Item  601(b)(31) of Regulation S-K.  Please
revise these certifications to include the introductory language of paragraph 4 and the language of paragraph 4(b) of It em 601(b)(31) of Regulation S-K.
   Please note that the failure to perform management’s assessment adversely affects
the company’s and its shareholders ability to avail themselves of rules and forms that are predicated on the current or timely filing of Exchange Act reports.  For further information regarding these impacts, please see Compliance and Disclosure Interpretation 115.02, which you can find at http://www.sec.gov/divisions/corpfin/guidance/regs-kinterp.htm
.

Mr. Robert “Steve” Owens
Ring Energy, Inc.
February 3, 2010 Page 3

Report of Independent Registered Public Accounting Firm, page F-3
 2. We note your disclosure on page F-9 that “Because the Company has not been able to generate revenue from operation, substantial doubt remains about the Company’s ability to continue as a going concern.”  In light of this disclosure, please have your auditor provide us with an assessment to support its conclusion that a going concern explanatory para graph was not required under AU Section
508.
 Closing Comments

 Please respond to these comments within 10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested information.  Detailed letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your 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 Exchange Act of 1934 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.     In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:  ‚ the company is responsible for the adequacy and accuracy of the disclosure in the filing;
‚ staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments 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 Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.

Mr. Robert “Steve” Owens
Ring Energy, Inc. February 3, 2010 Page 4

You may contact Jennifer O’Brien at (202) 551-3721, or Kevin Stertzel at (202)
551-3723, if you have questions regarding comments on the financial statements and related matters.  Please contact me at (202) 551-3299 with any other questions.          S i n c e r e l y ,             Mark C. Shannon         B r a n c h  C h i e f