Mail Stop 3561
      November 17, 2005

Chet Kurzawski
President
Hurley Exploration Inc.
1600 Golf Road, Suite 1200
Rolling Meadows, IL 60008

      Re:	Hurley Exploration Inc.
      Amendment No. 1 to Registration Statement on Form SB-2
      Filed November 11, 2005
		File No. 333-126900

Dear Mr. Kurzawski:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  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.
1. We note your response to comment 3 in our letter dated August
22,
2005 and the revisions you have made in your Management`s
Discussion
and Analysis.  However, you still need to reconcile your risk
factor
discussion and Management`s Discussion and Analysis discussion as
it
relates to your growth strategy.  In your risk factor section you
focus on acquiring suitable companies while your Management`s
Discussion and Analysis discusses acquiring suitable exploration
properties.  Please revise.
2. Please update your registration statement to include financial
statements for the period ended September 30, 2005.  See Item
310(g)
of Regulation S-B.

*****

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate 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
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any 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.

      You may contact Robert Babula, Staff Accountant, at (202)
551-
3339 or Mike Moran, Accounting Branch Chief, at (202) 551-3841 if
you
have questions regarding comments on the financial statements and
related matters.  Please contact Scott Anderegg, Staff Attorney,
at
(202) 551-3342 or me at (202) 551-3720 with any other questions.


      					Sincerely,



      					H. Christopher Owings
      Assistant Director




cc: 	Gregg E. Jaclin
	Anslow & Jaclin, LLP
      Via Fax (732) 577-1188



Chet Kurzawski
Hurley Exploration Inc.
November 17, 2005
Page 1