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SEC Letter

Ring Energy, Inc.

18 ½ East State Street

Suite 202

Redlands, CA 92373

February 17, 2010

Mark C. Shannon, Branch Chief

United States Securities and Exchange Commission

Division of Corporate Finance

Mail Stop 4628

Washington, D.C. 20549-4628

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. Shannon,

We appreciate your comments in your letter dated February 3, 2010, to our annual report on Form 10-K for the year ended September 30, 2009 (our “2009 Annual Report”). Mr. Owens, our President, recently had surgery and has asked me to respond to the comments in your letter. We have restated your comments in italics before our response as follows:

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.

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 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.

Management has performed an assessment of internal control over financial reporting as of September 30, 2009; however, our 2009 Annual Report failed to concisely state that fact. We intend to file an amendment to our 2009 Annual Report on Form 10-K and have attached hereto a copy of the intended filing for your reference. This amendment sets forth the assessment performed by management.

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 Item 601(b)(31) of Regulation S-K.

We have revised the Principal Executive Officer and Principal Financial Officer certification as required under Item 601(b)(31) and have included a copy of the revised certification for your reference.

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 operations, 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 paragraph was not required under AU Section 508.

We have reviewed your comment with our auditor regarding their assessment to support the conclusion that a going concern paragraph was not required and have included with this letter a response from the auditor on this point. A copy of the financial statements with the revisions described in the letter from our auditor is included in the amended 2009 Annual Report.

Mark C. Shannon, Branch Chief

February 17, 2010

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In connection with this response, Ring Energy, Inc. (the “Company”) acknowledges that:

·

The Company is responsible for the adequacy and accuracy of the disclosures 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.

If you desire to discuss these comments please contact me at at (801) 860-2302. Inasmuch as we do not have a fax machine, if you desire to transmit any information by fax, please direct such correspondence to our new legal counsel, Ronald N. Vance, at (801) 446-8803.

Sincerely,

/s/ Denny W. Nestripke

Denny W. Nestripke, Chairman

Encl.

cc: Ronald N. Vance, Esq.

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UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-K/A-1

(Mark One)

 X .

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended September 30, 2009

     .

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from ________ to __________

Commission File Number: 333-140024

Ring Energy, Inc.

(Exact name of Registrant as specified in its charter)

NEVADA

 90-0406406

State or other jurisdiction of incorporation or organization

 I.R.S. Employer Identification No.

18 ½ East State Street, Suite 202, Redlands, CA

 92373

(Address of principal executive offices)

 (Zip Code)

Issuer’s telephone number, including area code: (909) 798-8394

Securities registered pursuant to Section 12(b) of the Act: None

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes      . No  X .

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the Exchange Act.  X .

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by section 13 or 15(d) of the Exchange Act during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. (1) Yes  X . No      . (2) Yes  X . No      .

Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K (§229.405) is not contained herein, and will not be contained, to the best of registrant’s knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K.       .

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or a smaller reporting company. See definitions of “large accelerated filer,” “accelerated filer,” and “smaller reporting company” in Rule 12b-2 of the Exchange Act. (Check one):

Large Accelerated Filer      .  Accelerated Filer      . Non-Accelerated Filer      . Smaller reporting company  X .

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).

     .

As of March 31, 2009, the aggregate market value of the registrant’s common equity held by non-affiliates was approximately $10,344,600 computed by reference to the average bid and asked price of the Common Stock. For the purpose of the foregoing calculation only, all directors and executive officers of the registrant are assumed to be affiliates of the registrant. Such determination should not be deemed an admission that such officers and directors are, in fact, affiliates of the registrant.

At December 23, 2009, there were 3,548,200 shares of the registrant’s Common Stock outstanding.

DOCUMENTS INCORPORATED BY REFERENCE None

EXPLANATORY NOTE

The purpose of this Amendment No. 1 is to respond to comments by the staff of the Commission in a letter dated February 3, 2010.

Item 8, FINANCIAL STATEMENTS, has been revised to include clarifications to the notes to our financial statements for the year ended September 30, 2009, which are included after the signature page of this amended report. The “going concern” paragraph previously included in the notes to the financial statements has been removed. In addition, the “Organization” and “Business Condition” paragraphs of Note 1: Organization and Summary of Significant Accounting Policies, of our financial statements have been revised to eliminate the reference to pre-exploration stage and to designate the company as development stage.

Item 9A(T), Controls and Procedures, has been revised include the assessment by management of internal control over financial reporting as of September 30, 2009. In addition the certifications of our Principal Executive Officer and our Principal Financial Officer under Item 601(b)(31) of Regulation S-K have been revised and are included as exhibits to this amended report.

This Amendment No. 1 continues to speak as of the date of the original Form 10-K for the year ended September 30, 2009, and the Company has not updated or amended the disclosures contained in the amended items to reflect events that have occurred since the filing of the original Form 10-K, or modified or updated those disclosures in any way other than as described in the preceding paragraph. Accordingly, this Amendment No. 1 should be read in conjunction with the Company’s filings made with the SEC subsequent to the filing of the original Form 10-K on December 29, 2009.

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Item 8. Financial Statements

The financial statements required by this item are included immediately following the signature page of this report.

Item 9A(T). Controls and Procedures

Disclosure Controls and Procedures

Our principal executive and financial officer, Robert “Steve” Owens, has concluded, based on his evaluation, as of the end of the period covered by this report, that our disclosure controls and procedures (as defined in Rule 15d-15(e) under the Exchange Act) are (1) effective to ensure that information required to be disclosed by us in reports filed or submitted by us under the Exchange Act is recorded, processed, summarized, and reported within the time periods specified in the rules and forms of the Securities and Exchange Commission, and (2) designed to ensure that information required to be disclosed by us in such reports is accumulated, organized and communicated to our management, including our principal executive officer and principal financial officer, as appropriated, to allow timely decisions regarding required disclosure.

Management’s Report on Internal Control over Financial Reporting

Our management is responsible for establishing and maintaining adequate internal control over financial reporting to provide reasonable assurance regarding the reliability of our financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. Internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of the assets of our company; (ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of our management and directors; and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the company’s assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Management assessed our internal control over financial reporting as of September 30, 2009, the end of our fiscal year. Management based its assessment on criteria established in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission. Management’s assessment included evaluation of such elements as the design and operating effectiveness of key financial reporting controls, process documentation, accounting policies, and our overall control environment.

We believe the internal controls we have implemented are reasonable. Our principal weakness is that management is represented by only one individual and as such: (i) one individual incurs an obligation or liability and the same person approves payment of that obligation or liability; (ii) estimates and assumptions may not be objective; and (iii) the administration of our controls and procedures are not independent of management. Management is aware of the need for strong internal controls and is utilizing the audit committee of the Board of Directors to review its internal controls on a continuing basis.

Based on our assessment, management has concluded that our internal control over financial reporting was effective, as of September 30, 2009, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external reporting purposes in accordance with generally accepted accounting principles.

This annual report does not include an attestation report of the company's registered public accounting firm regarding internal control over financial reporting. Management's report was not subject to attestation by the company’s registered public accounting firm pursuant to temporary rules of the Securities and Exchange Commission that permit the company to provide only management's report in this annual report.

Changes in Internal Control over Financial Reporting

There were no changes in our internal control over financial reporting (as defined in Rule 15d-15(f) under the Exchange Act) that occurred during the fourth fiscal quarter ended September 30, 2009, that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

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Part IV

ITEM 15. EXHIBITS and Financial Statement Schedules

Exhibits

The following exhibits are included with this report:

Item 31.1

Rule 15d-14(a) Certification by Principal Executive Officer and Principal Financial Officer

SIGNATURE PAGE

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this amended report to be signed on its behalf by the undersigned, thereunto duly authorized.

Ring Energy, Inc.

Date: February 18, 2010

By: /s/ Robert “Steve” Owens

Robert “Steve” Owens, President

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Ring Energy, Inc.

(formerly Transglobal Mining Corp.)

(a development stage entity)

Balance Sheets

 September 30,

 2009

 2008

Assets:

Current Assets:

Cash and cash equivalents

 $

 1,050,915

 $

 87,296

Deposits

 1,884

 -

Prepaid expenses

 1,405

 57,228

Total Current Assets

 1,054,204

 144,524

Office Furniture (net)

 7,293

 -

Oil and Gas Interest (net)

 25,780

 -

Other Assets:

Available-for-sale securities

 -

 1,249,614

Total Other Assets

 -

 1,249,614

Total Assets

 $

 1,087,277

 $

 1,394,138

Liabilities and Stockholders' Equity:

Current Liabilities:

Accounts payable and accrued liabilities

 $

 136

 $

 941

Oil and gas drilling and operating costs payable

 27,613

 -

Total Current Liabilities

 27,749

 941

Total Liabilities

 27,749

 941

Stockholders' Equity:

Common Stock, $0.001 par value, 75,000,000 shares

authorized, 3,548,200 shares and 3,541,217 shares

issued and outstanding at September 30, 2009 and

2008, respectively

 3,548

 3,541

Paid-in capital

 1,671,741

 1,671,748

Accumulated other comprehensive loss

 -

 (386)

Deficit accumulated during the development stage

 (615,761)

 (281,706)

Total Stockholders' Equity

 1,059,528

 1,393,