CORRESP 1 filename1.htm
BARNETT & LINN
ATTORNEYS AT LAW
23564 Calabasas Road, Suite 205 • Calabasas, CA 91302
www.barnettandlinn.com
WILLIAM B. BARNETT TELEPHONE: 818-436-6410
Attorney/Principal FACSIMILE: 818-223-8303
  wbarnett@wbarnettlaw.com

 

October __, 2014

 

Division of Corporation Finance

Securities and Exchange Commission

100 F Street NE

Washington D.C. 20549

 

Attn: Karl Hiller, Branch Chief

Michael Fay, Staff Accountant

 

Re: New Western Energy Corporation (“Registrant”)

Amendment No. 2 to Form 10-K for the fiscal year ended December 31, 2013

Filed on April 14, 2014

File No. 000-54343

 

Attn: Karl Hiller, Branch Chief  
  Michael Fay, Staff Accountant  

 

     
  Re: New Western Energy Corporation (“Registrant”)
    Amendment No. 2 to Form 10-K for the fiscal year ended December 31, 2013
    Filed on April 14, 2014
    File No. 000-54343

 

Gentlepersons:

 

The Registrant hereby files its Amendment No. 2 to Form 10-K for the fiscal year ended December 31, 2013 (“Amendment No. 2”). The Amendment No. 2 has been revised in accordance with the Commission’s October 8, 2014 comment letter (“Comment Letter”).

 

To assist the staff in its review of Registrant’s responses, we have provided a copy of Amendment No. 2 “marked to show changes”, and our responses below correspond to each comment number in the Comment Letter.

 

Form 10-K/A for the Fiscal Year ended December 31, 2013

 

Description of Business, page 2

 

1.                  In accordance with your comment we have revised the disclosure throughout the entire Amendment 2 to encompass all narratives (including “Notes to Financial Statements”) relating to the lack of oil and gas reserves to adhere to the requirements of the SEC including those set forth in Subpart 229.1200 and Rule 4-10(a) of Regulation S-K and the Commission’s Compliance and Disclosure Interpretations of the Oil and Gas Rules.

In addition, we have revised Item 9A Controls and Procedures on page 27 to disclose a material weakness relating to the classification, categorizing and disclosure oil and gas reserves.

 
 

 

We believe that we have responded to all of your comments fairly and reasonably. Please contact the undersigned as soon as possible should you have any further questions or comments.

 

Thank you in advance for your courtesies and cooperation.

 

 

Very truly yours,

Barnett & Linn

 

 

 

William B. Barnett

 

 

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cc/ Mr. Khazali, CEO