SecProbe.io

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

     DIVISION OF
COR    MAIL STOP 7010 PORATION FINANCE
        October 17, 2008
By U.S. Mail and Facsimile

Mr. Harry Bydgnes, President Ibex Resources Corporation c/o Nevada Agency and Trust Company 50 West Liberty Street, Suite 880  Reno, NV 89501

Re: Ibex Resources Corporation
 Registration Statement on Form S-1
  File No. 333-153881   Filed October 7, 2008

Dear Mr. Bydgnes:

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.  If you disagree,
we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detaile d as necessary in your explan ation.  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 any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Directors, Executive Officers, Promoters and Control Persons, page 34

1. Please revise or supplement the biogra phical disclosure of your principal
executive officer and director, Harry B ygdnes, to include a description of his
business experience during the five years that immediately preceded the filing of
your registration statement

Closing Comments

 Please amend your registration statement in response to this comment.  You may
wish to provide us with marked copies of th e amendment to expedite our review.  Please
furnish a cover letter with your amendment th at keys your responses to our comments

Mr. Harry Bygdnes
Ibex Resources Corporation
October 17, 2008
Page 2

and provides any requested supplemental info rmation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendment and responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision.  Since the company and its
management are in possession of all facts re lating 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 this action as  a defense in any proceeding initiated by
the Commission or any person under the fe deral 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 a confirmation of th e fact that those reque sting 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 acce leration of the effective date.
  We direct your attention to Rules 460 and 461 regarding requesting acceleration of a registration statement.  Please allow adequa te time after the filing of an amendment for
further review before submitting a request for acceleration.  Please provide this request at
least two business days in advance of the requested effective date.

Mr. Harry Bygdnes
Ibex Resources Corporation
October 17, 2008
Page 3

 Please contact John Lucas at (202) 551-5798 or, in his absence, Carmen Moncada-Terry at (202) 551-3687 with any questions.

Sincerely,

 H. Roger Schwall Assistant Director
 cc: Ibex Resources Corporation
Attn: Harry Bydgnes, President 530-1015 4
th Street, S.W.,
Calgary, Alberta, T2R 1J4, Canada