Kodiak Energy, Inc. Watch

from 10-K 8 pages Please Understand That the Purpose of Our Review Is to Assist You in Your Compliance With the Applicable Disclosure Requirements and to Enhance the Overall Disclosure in Your Filings. 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 Contact US at the Telephone Numbers Listed at the End of This Letter. Form Sb-2 Filed November 13, 2007 1) Please Update Your Financial Statements and Other Financial Discussion. Refer to Rule 3-12 of Regulation S-X. 2) We Note Your Announcement That, Effective December 3, 2007, Mark Hlady Resigned From the Position of Chief Executive Officer and William Tighe Became Your Chief Executive Officer. Please Update the Disclosure Throughout Your Filing to Reflect Such Changes. Compensation Discussion and Analysis, Page 33

from SB-2 9 pages Nature of Work

from SB-2 9 pages Nature of Work

from SB-2 9 pages Nature of Work

from SB-2 9 pages Nature of Work

from SB-2 44 pages Agreement of Purchase and Sale

from SB-2 47 pages Agency Agreement

from SB-2 47 pages Agency Agreement

from SB-2 27 pages Kodiak Energy, Inc. – Flow-Through Subscription Agreement

from SB-2 23 pages Kodiak Energy, Inc. – Common Shares Subscription Agreement

from SB-2 27 pages Kodiak Energy, Inc. – Flow-Through Subscription Agreement

from SB-2 23 pages Kodiak Energy, Inc. – Common Shares Subscription Agreement

from S-8 1 page 2002-B Consultants Compensation Plan

from S-8 1 page Material contract

from SB-2/A ~10 pages Material contract

from SB-2/A ~10 pages Material contract

from SB-2/A ~10 pages Material contract

from SB-2/A ~5 pages Material contract

from SB-2/A 1 page Material contract

from SB-2/A ~5 pages Material contract