[GULFPORT LETTERHEAD]
January 18, 2007
Securities and Exchange Commission
450 Fifth Street, N.W.
Mail Stop 7010
Washington, D.C. 20549
Attn: | Karl Hiller |
Nasreen Mohammed |
Re: | Gulfport Energy Corporation |
Annual Report on Form 10-KSB, File No. 0-19514, filed on March 31, 2006 (the Form 10-KSB) |
Quarterly Report on Form 10-QSB, File No. 0-19514, filed on November 13, 2006 (Form 10-QSB) |
Dear Mr. Hiller:
On behalf of Gulfport Energy Corporation, a Delaware corporation (the Company), we enclose for filing this letter revising the Companys response #4 contained in its letter, dated January 5, 2007, to the Securities and Exchange Commission Staff (the Staff) in response to the Staffs comment letter, dated December 12, 2006 (the Comment Letter). The Company has revised response #4 based upon its telephone conversation with the Staff on January 17, 2007. For your convenience, revised response #4 is preceded by the Staffs comment #4 set forth in the Comment Letter.
Form 10-KSB for the Year Ended December 31, 2005
Note 13 Financial Instruments and Hedging Activities, page F-19
4. | Comment. You disclose that 540,000 barrels of estimated future production were hedged at December 31 2005. It would be helpful to have also disclosed the percentage of your estimated production for the coming year that was covered by these fixed-price contracts. |
Response: We historically have not had a practice of disclosing projections of production in our filings under the Securities Exchange Act of 1934, as amended (the Exchange Act). In addition, we currently do not have any hedges in place for future periods. However, we note the Staffs comment and to the extent we hedge or enter into fixed-price contracts with respect to our production in the future, we will disclose the percentage of our estimated future production for the coming year covered by any such hedges or fixed-price contracts.
If you have any questions with respect to the foregoing, please call the undersigned at (405) 242-4408.
Sincerely,
/s/ Michael G. Moore
Michael G. Moore
Enclosures
cc: | Ben Russ |
General Counsel |
Seth R. Molay, P.C. |
Akin Gump Strauss Hauer & Feld LLP |
Alex Frutos |
Akin Gump Strauss Hauer & Feld LLP |