SecProbe.io

January 9 , 201 4

Via E -Mail
Mr. Brad Juneau
Contango Ore Inc.
3700 Buffalo Speedway, Suite 960
Houston, Texas 77098

Re: Contango Ore Inc.
 Form 10-K for Fiscal Year Ended  June 30 , 201 3
Filed September 11,  2013
File No. :  001 -35770

Dear Mr. Juneau :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstance s or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for Fiscal Year Ending June 30, 2013 filed September 11, 2013

Environmental regulation, page 14

1. We note you are subject to permitting requirements of the Bureau of Land Management
(BLM) and/or Forest Service in addition to State Environmental requirements.  Please
revise your filing and provide a short summary of the permits and/or operational plans
required to perform exploration and/or mining activities on your properties and discuss in
greater detail the government and environmental regulations to which you are subject .
Please fully discuss the permitting, bonding, and reclamation requirements for  each phase
of your exploration work including the specific permits and associated fees.  In your
discussion, include the specific permits that your company has obtained or will obtain to
perform each phase of you exploration program.  Describe the effect of existing or
probable governmental regulations on your business. See Item 101(h) (4) (viii), (ix) and
(xi) of Regulation S -K.

Mr. Brad Juneau
Contango Ore Inc.
January 9 , 201 4
Page 2

Location and Access to Our Properties, page 23

2. Please modify your filing and disclose the information required under paragraph  (b) of
Industry Guide 7 for all your material properties listed under this heading.  For any
properties identified that are not material, please include a statement to that effect,
clarifying your intentions.  For each material property, include the follo wing information:

 The location and means of access to your property, including the modes of
transportation utilized to and from the property.

 Any conditions that must be met in order to obtain or retain title to the property,
whether you have surface and /or mineral rights.

 A brief description  of the rock formations and mineralization of existing or potential
economic significance on the property.

 A description of any work completed on the property  and its present condition.

 The details as to modernization and physical condition of the plant and equipment,
including subsurface improvements and equipment.

 A description of equipment, infrastructure, and other facilities.

 The current state of exploration of the property.

 The total costs incurre d to date and all planned future costs.

 The source of power and water that can be utilized at the property.

 If applicable, provide a clear statement that the property is without known reserves
and the proposed program is exploratory in nature.

You may r efer to Industry Guide 7, paragraphs (b) (1) through (5), for specific guidance
pertaining to the foregoing, available on our website at the following address :
www.sec.gov/about/forms/indust ryguides.pdf

3. We note an empty graphic box in you r filing and believe this may have been a map.
Please revise your filing and insert a small -scale map showing the location and access to
each material property, as required by Instruction 3(b) to Item 102 of Regulation S -K.
Please note the EDGAR program now accepts Adobe PDF files and digital maps, so
please include these maps in any amendments that are uploaded to EDGAR.  It is
relatively easy to include automatic links at the appropriate locations within the document
to GIF or JPEG files, which will allow figures and diagrams to appear in the right
location when the document is v iewed on the Internet.  For more information, please

Mr. Brad Juneau
Contango Ore Inc.
January 9 , 201 4
Page 3

 consult the EDGAR manual, and if additional assistance is required, please call Filer
Support at (202) 551 -3600 for Post -Acceptance Filing Issues or (202) 551 -8900 for Pre -
Acceptance Filing Issues. We be lieve the guidance in Instruction 3(b) of Rule 102 of
Regulation S -K would generally require maps and drawings to comply with the following
features :

 A legend or explanation showing, by means of pattern or symbol, every pattern or
symbol used on the map o r drawing.

 A graphical bar scale should be included.  Additional representations of scale such as
"one inch equals one mile" may be utilized provided the original scale of the map has
not been altered.

 A north arrow.

 An index map showing where the property is situated in relationship to the state or
province, etc., in which it was located.

 A title of the map or drawing, and the date on which it was drawn.

 In the event interpretive data is submitted in conjunction with any map, the identity of
the geologist or engineer that prepared such data.

Any drawing should be simple enough or of sufficiently large scale to clearly show all
features on the drawing.

4. It appears you should also amend your filing and expand your disclosure concerning the
explorat ion plans for the properties to address the following points.

 Disclose a brief geological justification for each of the exploration projects written in
non-technical language.

 Give a breakdown of the exploration timetable and budget, including estimated
amounts that will be required for each exploration activity, such as geophysics,
geochemistry, surface sampling, drilling, etc. for each prospect.

 If there is a phased program planned, briefly outline all phases.

 If there are no current detailed plans to  conduct exploration on the property,  disclose
this prominently .

 Disclose how the exploration program will be funded.

 Identify who will be conducting any proposed exploration work, and discuss what
their qualifications are.

Mr. Brad Juneau
Contango Ore Inc.
January 9 , 201 4
Page 4

5. Detailed sampling provides  the basis for the quality estimate or grade of your mineral
discovery.  Please revise your filing and provide a brief description of your sample
collection in your amended filing along with your sample preparation and the analytical
procedures used to develo p your analytical results.  In addition, please disclose any
Quality Assurance/Quality Control (QA/QC) protocols you have developed for your
exploration program.  These procedures would serve to inform potential investors
regarding your sample collection a nd preparation, assay controls, sample custody, assay
precision and accuracy procedures and protocols.

6. We recommend that a brief description of the QA/QC protocols be provided to inform
readers regarding sample preparation, controls, custody, assay precis ion and accuracy as
it relates to your exploration plans.  This would apply to exploration and operational
analytical procedures.

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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accura cy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written 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.

You may contact George Schuler, Mining Engineer, at (202) 551 -3718 with questions
about the engineering comments.  Please contact me at (202) 551 -3795 with any other questions.

Sincerely,

        /s/ John Reynolds

John Reynolds
Assistant Director