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February 08, 2019

VIA EDGAR

Mr. Brad Skinner

Senior Assistance Chief Accountant

United States Securities and Exchange Commission

Division of Corporation Finance – Office of Natural Resources

Washington, DC 20549

 RE: Ring Energy, Inc.

Form 10-K for Fiscal Year Ended

December 31, 2017

File No. 001-36057

Dear Mr. Skinner:

Ring Energy, Inc., a Nevada corporation
(the “Company,” “we,” “us,” or “our”) is submitting this letter in response to
the comment letter from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
dated December 26, 2018 (the “Comment Letter”) with respect to the Company’s Annual Report on Form 10-K for the
fiscal year ended December 31, 2017 (File No. 001-36057) (the “Form 10-K”) filed with the Commission on March 15, 2018.

This letter sets forth the comments of
the Staff in the Comment Letter (numbered in accordance with the Comment Letter) and, following each comment, sets forth our response.

Form 10-K for the Fiscal Year Ended
December 31, 2017

Properties

Proved Undeveloped Reserves, page 17

 1. Expand your disclosure to discuss the investments and progress made during the year to convert
proved undeveloped reserves to proved developed reserves, including, but not limited, to the capital expenditures incurred during
the year. Also resolve the apparent inconsistency in the figures for the “future capital expenditures” and the “estimated
development costs” presented page 18. Refer to Item 1203(c) of Regulation S-K.

Ring Energy, Inc.

Form 10-K for Fiscal Year Ended

December 31, 2017

File No. 001-36057

Page 2

Response 1: The Company
respectfully acknowledges the Staff’s comment. Based on the foregoing, we will enhance disclosures relating to our investments
and progress made, and avoid any further inconsistencies. We will expand our disclosure to include costs incurred during the year
to convert proved undeveloped reserves to proved developed reserves substantially in the form as follows in future reports:

“During
the year ended December 31, 2018, we incurred costs of approximately $_____ million to convert the reserves associated with [_____
number] of our net proved undeveloped locations at December 31, 2018, to proved developed reserves of _____ MBoe.”

As to the discrepancy between
the “future capital expenditures” in the first table and the “estimated development costs” in the second
table, this is an inconsistency, as the amount shown for “future capital expenditures” in the first table did not include
all of the future development costs. The first table which included “future capital expenditures” should have reflected
the following amounts:

    Oil

                                                                                (Bbl)

    Gas

                                                                                (Mcf)

    Total

                                                                                (Boe)

    % of Total

 Proved
    Pre-tax PV10

 (In thousands)
    Standardized

 Measure of

 Discounted

 Future Net

 Cash Flows

 (In thousands)
    Future

 Capital

 Expenditures

 (In thousands)

         PDP
      12,515,600
      11,274,200
      14,394,633
      45 %
    $ 218,905
    $ 184,740
    $ -

         PDNP
      2,806,000
      1,400,000
      3,039,333
      10 %
      59,390
      50,120
      5,376

         PUD
      13,622,142
      5,363,289
      14,516,024
      45 %
      103,806
      87,605
      126,972

    Total Proved:
      28,943,742
      18,037,489
      31,949,990
      100 %
    $ 382,101
    $ 322,465
    $ 132,348

The amount shown as “estimated
development costs” in the second table, however, is correct and is the amount reflected elsewhere in the 2017 Annual Report
on Form 10-K. We do not believe this inconsistency is material, particularly in light of the information being provided accurately
in other locations within the report. We propose that the enhanced disclosure be provided in future reports and no remedial action
need be taken with respect to the 2017 Annual Report on Form 10-K.

Internal Controls Over Reserves Estimates,
page 18

 2. If you represent that your reserves were prepared or audited by third party independent consultants,
you must additionally disclose the qualifications of the technical person within each of the third party engineering firms, e.g.
Cawley, Gillespie & Associates, Inc. and Williamson Petroleum Consultants, Inc., primarily responsible for overseeing the preparation
of such estimates. Refer to the requirements pursuant to Item 1202(a)(7) of Regulation S-K.

Ring Energy, Inc.

Form 10-K for Fiscal Year Ended

December 31, 2017

File No. 001-36057

Page 3

Response 2: The Company
respectfully acknowledges the Staff’s comment. We agree to enhance the disclosure regarding the qualifications of the technical
person overseeing the preparation of any third party engineering reports and estimates. The enhanced disclosure shall be substantially
in the form as follows:

“Approximately
100 percent of the proved reserves estimates shown in the Annual Report on Form 10-K at December 31, 2018, have been independently
prepared by Cawley, Gillespie & Associates (“CGA”), a leader of petroleum property analysis for industry and financial
institutions. CGA was founded in 1960 and performs consulting petroleum engineering services under Texas Board of Professional
Engineers Registration No. F-693. Within CGA, the technical person primarily responsible for preparing the estimates set forth
in the CGA letter dated [January _____, 2019], filed as an exhibit to this Annual Report on Form 10-K, was Mr. Zane Meekins. Mr.
Meekins has been a practicing consulting petroleum engineer at CGA since 1989. Mr. Meekins is a Registered Professional Engineer
in the State of Texas (License No. 71055) and has over 30 years of practical experience in petroleum engineering, with over 28
years of experience in the estimation and evaluation of reserves. He graduated from Texas A&M University in 1987 with a Bachelor
of Science degree in Petroleum Engineering. Mr. Meekins meets or exceeds the education, training, and experience requirements set
forth in the Standards Pertaining to the Estimating and Auditing of Oil and Gas Reserves Information promulgated by the Society
of Petroleum Engineers; he is proficient in judiciously applying industry standard practices to engineering and geoscience evaluations
as well as applying SEC and other industry reserve definitions and guidelines.”

With respect to Williamson Petroleum
Consultants, Inc. (“Williamson”), Williamson has advised us that its principals retired last year in 2018, and we will
not be utilizing Williamson in connection with the reserve report to be included with our Annual Report on Form 10-K for the year
ended December 31, 2018. We propose that we make the enhanced disclosures relating to any current or future reserve engineers in
future reports.

Acreage, page 19

 3. Expand your disclosure to provide the expiration dates of material amounts of undeveloped
acreage. Refer to Item 1208(b) of Regulation S-K.

Ring Energy, Inc.

Form 10-K for Fiscal Year Ended

December 31, 2017

File No. 001-36057

Page 4

Response 3: We respectfully
acknowledge the Staff’s comments and note we will enhance our disclosures to include material acreage that will expire, unless
developed or renewed, during each of the next three years. We plan to include a disclosure substantially in the form as follows:

“Leases of undeveloped
acreage will generally expire at the end of their respective primary terms unless production from such leasehold acreage has been
established prior to expiration of such primary term. If production is established on such acreage, the lease will generally remain
in effect until the cessation of production from such acreage and is referred to in the industry as “Held-By-Production”
or “HBP.” Leases of undeveloped acreage may terminate or expire as a result of not meeting certain drilling commitments,
if any, or otherwise by not complying with the terms of a lease depending on the specific terms that are negotiated between lessor
and lessee.

The following table sets forth
the gross and net undeveloped acreage, as of December 31, 2018, under lease which would expire over the next three years unless
(i) production is established on the lease or within a spacing unit of which the lease is participating, or (ii) the lease is renewed
or extended prior to the relevant expiration dates:

      2019
      2020
      2021

      Gross
      Net
      Gross
      Net
      Gross
      Net

    Undeveloped Acreage

    Total

 4. Tell us the extent to which you have assigned any proved undeveloped reserves to locations
which are currently scheduled to be drilled after lease expiration. If there are material quantities of net proved undeveloped
reserves relating to such locations, expand your disclosure to identify the number of locations, the related net reserve quantities
and the steps which would be necessary to extend the time to the expiration of such leases. Refer to Rule 4-10(a)(26) of Regulation
S-X.

Response 4: We respectfully
acknowledge the Staff’s comments. We have not assigned any proved undeveloped reserves to locations which are currently scheduled
to be drilled after lease expiration. We will not drill on any expired leases, unless we have significant assurances such lease
will be renewed or extended. We have not drilled on acreage covered by an expired lease and do not expect to drill on acreage covered
by an expired lease in the future. In the event that this changes in the future, we will include a disclosure outlining the items
requested in Comment 4 above. Additionally, we will not assign any proved undeveloped reserves to locations which are scheduled
to be drilled after lease expiration.

Ring Energy, Inc.

Form 10-K for Fiscal Year Ended

December 31, 2017

File No. 001-36057

Page 5

Production History, page 19

 5. Tell us how you considered the requirements with regard to disclosure of production, by final
product sold, for each individual field that contains 15% or more of your total proved reserves. Refer to Item 1204(a) of Regulation
S-K and Rule 4-10(a)(15) of Regulation S- X.

Response 5: We respectfully
acknowledge the Staff’s comment and note that all of the products we sell are included in our disclosure of production, namely
oil and natural gas. We sell our gas at the wellhead and, accordingly, account for it as natural gas sales. We do not have any
natural gas liquids or condensate sales, given our natural gas is sold at the wellhead. With respect to our upcoming 2018 Annual
Report on Form 10-K, we will expand this disclosure to reflect the production from each of the Central Basin Platform and the Delaware
Basin as these are the only two fields that contain 15% or more of the total proved reserves attributable to the underlying properties.
We respectfully propose to include a footnote in our table under “Production History” in our Form 10-K, which sets
forth the amount of production derived from both fields substantially in the form as follows:

“Production
from the Central Basin Platform field during the years ended December 31, 2016, 2017 and 2018 was _____, _____ and _____ MBoe,
respectively, consisting of ____, _____ and _____ MBbls of oil, respectively, and _____ ,______and _____ MMcf of natural gas, respectively.
Production from the Delaware Basin field during the years ended December 31, 2016, 2017 and 2018 was ___, _____ and ____ MBoe,
respectively, consisting of ____, ____ and _____ MBbls of oil, respectively, and _____, ____ and ____ MMcf of natural gas, respectively”.

Drilling Activity, page 20

 6. Expand your disclosure to additionally provide the total number of net development wells
drilled, the total number of net exploratory wells drilled and the extent that you drilled any dry development and/or exploratory
wells. Refer to Item 1205 of Regulation S-K. Also modify your use of the term “science wells” to conform your disclosure
to one of the well types identified in Item 1205(b)(2) of Regulation S-K or in Rule 4-10(a) of Regulation S- X.

Response 6: We agree
to enhance our disclosure to provide the total number of net development wells drilled, the total number of net exploratory wells
drilled, and any dry development or exploratory wells. We propose providing such enhanced disclosure in our upcoming 2018 Annual
Report on Form 10-K. If permitted to do so in the 2018 Annual Report on Form 10-K, we will change to a tabular format and expand
the disclosure to include both gross and net wells for all categories substantially in the form as follows:

Ring Energy, Inc.

Form 10-K for Fiscal Year Ended

December 31, 2017

File No. 001-36057

Page 6

      Year
                                         Ended December 31,

      2018
      2017
      2016

      Gross
      Net
      Gross
      Net
      Gross
      Net

    Exploratory:

    Productive

    Dry

    Development:

    Productive

    Dry

    Total:

    Productive

    Dry

Please note that all of the
wells drilled by the Company to date have been development wells, with the exception of the three “science wells.”
“Science well” is a term used in the industry to describe a well that is drilled for purposes of determining the stratigraphic
composition of a particular area and is not intended to be completed and produce any oil or gas. Going forward, we will designate
the “science wells” as exploratory wells; in addition, since these exploratory wells were not completed for production,
we will designate them as dry wells. We would propose to then footnote that these were stratigraphic test wells that were never
intended to be completed for production. The proposed footnote would read substantially in the form as follows:

“Footnote 1: The exploratory wells drilled in
2017 are what we previously termed science wells. The wells were stratigraphic test wells and were drilled without the intention
of completing them for production. Since they were not completed for production, they have been classified as dry wells.”

We believe this approach is
consistent with the manner in which other registrants that operate in the surrounding area would report their results.

Ring Energy, Inc.

Form 10-K for Fiscal Year Ended

December 31, 2017

File No. 001-36057

Page 7

 7. Expand the disclosure of your drilling activities to additionally discuss your present activities,
such as the number of wells in the process of being drilled (including wells temporarily suspended), waterfloods in the process
of being installed, pressure maintenance operations, and any other related activities of material importance subsequent to the
fiscal year-end. Refer to Item 1206 of Regulation S-K.

Response 7: We respectfully
acknowledge the Staff’s comment and agree to enhance our disclosure of drilling activities and other operations. We are no
longer conducting water floods. We respectfully propose to the Staff that we address the expanded disclosure in our upcoming 2018
Annual Report on Form 10-K. If permitted to do so in the 2018 Annual Report on Form 10-K, we will add language substantially in
the form as follows:

“During
2018, the Company drilled ___ gross horizontal wells (___net), completed _____ gross (___ net) horizontal wells and drilled and
placed into service _____ gross (___ net) salt water disposal wells. All wells are in the State of Texas. We did not install any
new water flood operations or suffer any material mechanical failures during 2018 and there were no material suspensions of production
during 2018. As of December 31, 2018, the Company was in the process of drilling ___ gross (___ net) horizontal wells and completing
____ gross (___ net) horizontal wells. No other material activities were in process as of December 31, 2018.”

Financial Statements

Notes to Financial Statements

Note