July 9, 2019

James J. Huang
Chief Investment Officer
Indonesia Energy Corporation Limited
Dea Tower I, 11th Floor, Suite 1103
Jl. Mega Kuningan Barat Kav. E4.3 No.1-2
Jakarta 12950, Indonesia

       Re: Indonesia Energy Corporation Limited
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted April 10, 2019
           CIK No. 0001757840

Dear Mr. Huang:

      We have reviewed your amended draft registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-1 as Amended June 28, 2019

Prospectus Summary
Indonesia's Oil and Gas Industry and Economic Information, page 1

1.     Here and throughout your filing you reference statistics and information
relevant to your
       industry. Please revise to specifically attribute the statements to a
source. For example,
       we note your statement that Indonesia has an average GDP "growth of
above 5% for the
       past 10 years based on publicly available information."
 James J. Huang
FirstNameEnergy Corporation Huang
Indonesia LastNameJames J. Limited
Comapany NameIndonesia Energy Corporation Limited
July 9, 2019
July 9, 2019 Page 2
Page 2
FirstName LastName
Risk Factors
We may not adhere to our proposed drilling schedule, page 20

2.       Provide us with your development schedules, indicating for each future
annual period and
         for each category of reserves, the number of gross wells to be
drilled, the net quantities of
         reserves and estimated capital expenditures necessary to convert all
of the proved and
         probable undeveloped reserves disclosed as of December 31, 2018 to
developed reserves.
         Refer to Rule 4-10(a)(31)(ii) of Regulation S-X and the Question
131.04 in the
         Compliance and Disclosure Interpretations (C&DIs), issued October 26,
2009 and updated
         May 16, 2013, and tell us if all of the undeveloped locations in the
foregoing annual
         schedules are part of a development plan adopted by the management
including approval
         by the Board, if such approval is required.
Our business requires significant capital investment...,, page 25

3.       Your calculation of the standardized measure of discounted future net
cash flows on page
         F-27 indicates that you expect to incur $42.9 million in future
development costs relating
         to the proved reserves disclosed as of December 31, 2018. Tell us how
you concluded that
         there is a reasonable expectation that the required financing will
exist to fund these
         development costs. For example, explain in greater detail your plans
to finance capital
         expenditures through cash generated by your operations and potential
future financing
         arrangements. Refer to Rule 4-10(a)(26) of Regulation S-X.

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources, page 54

4.       You state that your current cash and cash equivalents and anticipated
cash flows from
         operating and financing activities will be sufficient to meet your
near term anticipated
         working capital requirements and capital expenditures. Revise to
provide additional
         disclosure clarifying your liquidity position and describing the
anticipated source of funds
         needed to fulfill your material commitments. Refer to Items 303(a)(1)
and (2) of
         Regulation S-K.
Management's Discussion and Analysis of Financial Conditions and Results of
Operations
Business
Kruh Block, page 62

5.       We have read your response to comment 15 but are unable to locate your
expanded
         disclosure providing an explanation of the material changes in your
proved undeveloped
         reserves that occurred during the year ended December 31, 2018.

         In this regard, your explanation should be in sufficient detail to
identify the individual
         factors such as the conversion of proved undeveloped reserves to
proved developed status,
 James J. Huang
FirstNameEnergy Corporation Huang
Indonesia LastNameJames J. Limited
Comapany NameIndonesia Energy Corporation Limited
July 9, 2019
July 9, 2019 Page 3
Page 3
FirstName LastName
         revisions of the previous estimates of reserves, improved recovery,
extensions and
         discoveries, acquisitions, and divestitures that caused your proved
undeveloped reserves
         to increase from "0" at December 31, 2017 to 1,964,370 barrels of oil
at December 31,
         2018. To the extent that two or more factors, including offsetting
factors contribute to a
         material change, indicate the net amount attributable to each factor
accompanied by a
         narrative explanation.

         The disclosure of revisions in the previous estimates of reserves in
particular should
         identify such factors as changes caused by commodity prices, changes
in contract terms or
         duration, well performance, unsuccessful and/or uneconomic proved
undeveloped
         locations or the removal or addition of proved undeveloped locations
due to changes in a
         previously adopted development plan. Refer to the disclosure
requirements for proved
         undeveloped reserves under Item 1203(b) of Regulation S-K.
6.       Expand the discussion relating to your proved undeveloped reserves to
quantify the
         amount of capital expenditures incurred during the year ended December
31, 2018 to
         convert proved undeveloped reserves to proved developed reserves.
Refer to Item 1203(c)
         of Regulation S-K.
7.       Expand your disclosure to discuss the progress made during 2018, and
any factors that
         impacted progress in converting proved undeveloped reserves to
developed status. Refer
         to Item 1203(c) of Regulation S-K.
8.       Your response to comment 13 explains that you have not yet obtained
conclusive results
         on the efficiency of the "electrical stimulation oil recovery method
(ESOR)" and whether
         you will continue its application to the Kruh Block. Tell us the
extent that you have
         assigned proved and/or probable reserves to be recovered using the
ESOR recovery
         method as part of the reserves disclosed as of December 31, 2018.
Refer to Rule 4-
         10(a)(25) of Regulation S-X.
Notes to Consolidated Financial Statements
Supplementary Information for Oil and Gas Producing Activities (Unaudited)
Proved Reserves the Company Expects to Lift in Kruh Block, page F-25

9.       Expand the disclosure relating to the changes in the net quantities of
total proved reserves
         to provide an appropriate narrative explanation for the significant
changes relating to each
         line item entry within the reconciliation other than production, e.g.
the changes you have
         identified relating to the revisions of previous estimates and changes
relating to extensions
         and discoveries for the period ending December 31, 2018. The
explanation should
         address the change for the line item by separately identifying and
quantifying each factor,
         including offsetting factors, that contributed to a significant change
so that the change in
         net reserves between periods is fully explained. To the extent that
two or more factors
         contribute to a significant change, indicate the net amount
attributable to each factor
         accompanied by a narrative explanation.
 James J. Huang
FirstNameEnergy Corporation Huang
Indonesia LastNameJames J. Limited
Comapany NameIndonesia Energy Corporation Limited
July 9, 2019
Page 4
July 9, 2019 Page 4
FirstName LastName


         The disclosure of revisions in the previous estimates of reserves in
particular should
         identify and separately quantify changes due to such unrelated factors
as changes caused
         by commodity prices, changes in contract terms or duration, well
performance,
         unsuccessful and/or uneconomic proved undeveloped locations or the
removal or addition
         of proved undeveloped locations due to changes in a previously adopted
development
         plan. This comment applies to the reconciliation of the changes in
total net proved
         reserves for the periods ending December 31, 2018 and 2017,
respectively. Refer to
         FASB ASC 932-235-50-5.
10.      The reconciliation of the changes in total gross and net proved
reserves for the period
         ending December 31, 2017 does not appear to address the significant
changes, other than
         production that occurred during the year, e.g. the significant
increase in proved developed
         gross and net reserves from 263,113 to 301,748 gross barrels and from
195,690 to 224,426
         net barrels, and the significant decrease in proved undeveloped gross
and net reserves
         from 137,080 to 0 gross barrels and from 101,953 to 0 net barrels.
Revise your disclosure
         to conform to the disclosure requirements pursuant to FASB ASC
932-235-50-5 or tell us
         why a revision is not necessary.
Standardized Measure of Discounted Future Net Cash Flows Relating to Proved Oil
and Gas
Reserves, page F-26

11.      The disclosure relating to the standardized measure indicates you
computed the future
         cash flows by applying the "previous 12 months average price" to the
year-end quantities
         of proved reserves. Tell us if the average prices you used, as shown
in the table on page
         F-27, were determined in accordance with Rule 4-10(a)(22)(v) of
Regulation S-K "as the
         unweighted arithmetic average of the first-day-of-the-month price for
each month within
         the previous 12 months."
12.      Tell us if the costs associated with the abandonment of your proved
undeveloped
         locations, have been included in the calculation of the standardized
measure as of
         December 31, 2018. If such costs have been omitted, explain to us your
basis for
         excluding these costs from your calculation of the standardized
measure.
 James J. Huang
Indonesia Energy Corporation Limited
July 9, 2019
Page 5

        For questions regarding comments on engineering matters, you may
contact John
Hodgin, Petroleum Engineer, at (202) 551-3699. You may contact Jeannette Wong,
Staff
Accountant, at (202) 551-2137 or Ethan Horowitz, Accounting Branch Chief, at
(202) 551-3311
if you have questions regarding comments on the financial statements and
related matters.
Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or, in
her absence,
Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642 with any other
questions.



FirstName LastNameJames J. Huang                        Sincerely,
Comapany NameIndonesia Energy Corporation Limited
                                                        Division of Corporation
Finance
July 9, 2019 Page 5                                     Office of Natural
Resources
FirstName LastName