Mail Stop 4561

                                                      January 6,
2006



John M. James
Chief Financial Officer and Secretary
303 West Wall Street, Suite 2300
Midland, TX 79071

Re:	AMEN Properties, Inc.
	File No. 000-22847
      Form 10-KSB for the Fiscal Year Ended
      December 31, 2004
Forms 10-QSB for the Quarterly Periods Ended
March 31, 2005 and June 30, 2005



Dear Mr. James:

      We have reviewed your response letter dated September 15,
2005
and have the following additional comment.  Where indicated, we
think
you should revise your document in response to this comment.  If
you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.

	Please understand that the purpose of our review 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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K/A for the year ended December 31, 2004

Item 8a Controls and Procedures, page 15

1. We have considered your response to our prior comments one and
two
and the related changes to your  disclosure of controls and
procedures.  Please  revise to disclose how you determined that
your
disclosure controls and procedures were effective as of December
31,
2004 despite the material error that led to the  restatement of
your
financial statements. Also, disclose the steps that you are taking
to
remediate the material weakness.


*    *    *    *

      Please amend your filing and respond to this comment within
10
business days or tell us when you will provide us with a response.
Please file your response letter on EDGAR.  Please understand that
we
may have additional comments after reviewing your amendment and
response to our comment.

      You may contact Robert Telewicz, Staff Accountant, at (202)
551-3438 or the undersigned at (202) 551-3413 if you have
questions.



Sincerely,



Jorge L. Bonilla
Senior Staff Accountant



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John M. James
Amen Properties, Inc.
January 6, 2006
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