May 7, 2013
BY FEDERAL EXPRESS
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, Mail Stop 7010
Washington, DC 20549
Attn:  Caroline Kim and Anne Nguyen Parker

RE:   Amerigo Energy, Inc.  -    Form 8-K Filed February 27, 2013

Dear Ms. Kim and M. Parker:

      On  behalf of registrant, Amerigo Energy, Inc., we hereby respond to your
comment letter  of  March  18, 2013 in the same sequence in which your comments
are noted.

      In regards to your request  for  information  required by Item 2.01(f) of
Form 8-K and the related financial information.

We  are  amending  the  8K to add the additional risk factors  and  information
related to this line of business  and  anticipate  filing  the  amendment  here
shortly.   The assets acquired were intangible in nature so this was in essence
a small company  acquiring  the  assets  of  another  small company. We believe
including the information as it relates to a Form 10 would  be  different as we
have  not  acquired  a  business.   The  acquisition has allowed us to  open  a
different division of our existing business.

      In regards to your question related  to  the  company  appearing  to be a
shell company.

We respectfully disagree based on our belief we do not meet the test.  We  have
been  exploring  opportunities for the company to diversify its investments and
the implementing of  our  business  plan  has gone slower than as expected. The
recent acquisition of the license agreement  and trademarks for Le Flav Spirits
was one of many things the company is doing in its diverse investment plan.

We have reviewed the referenced SEC Releases in so far as it relates to being a
shell company and we believe this furthers our  belief.   In the examples given
in  SEC Release No. 33-8587, there are two forms, neither of  which  appear  to
apply  to  our  situation.   There  was  no  business  acquired and "the former
shareholders of the private business controlling the surviving  entity" did not
occur.  The shares issued in relation to the transaction were less  than  5% of
the  shares  outstanding  in  the  company.  Amerigo Energy Inc. has no present
plans, nor any of our shareholders,  have  plans  to  enter  into  a  change of
control or similar transaction.

There were few shares issued for the purchase of the license agreement.   There
has been no change in control or management of the company.  The 2011 Form 10K,
referenced  in  your letter, while indicating the minimal assets, also reflects
$37,000 in revenue  from  the  oil  and  gas  assets  of  the company which for
accounting  purposes  had  been  reduced  on  the  face  of the balance  sheet.
Additionally the company has made significant strides to reduce the outstanding
debt,  which  has  in  part  slowed, but has not forced an abandonment  of  the
implementation of the existing business plan.

As mentioned in our recently filed 2012 Form 10-K, we stated:

        The Amerigo Energy's business  plan  included  developing oil
        and  gas reserves while increasing the production  rate  base
        and cash flow. The plan was to continue acquiring oil and gas
        leases   for   drilling   and  to  take  advantage  of  other
        opportunities and strategic  alliances.  Due  to  declines in
        production on the oil leases the company had an interest  in,
        the  company  has  been forced to explore its position in the
        oil  industry.  In 2011,  the  company  began  an  aggressive
        approach to reduce the debt on the company's books as well as
        looking to diversify  the  investment  holdings,  while still
        maintaining  limited  interest in oil leases. The company  is
        aggressively looking for  potential  oil leases to acquire as
        well  as  businesses  which  will  fit  with   the  company's
        strategy.   Analyzing  opportunities  in the oil industry  as
        well  as  other potential investments has  gone  slower  than
        planned, but  the  company  is  committed to implementing its
        business plan.


Please  let  us  know if you have further questions  and  we  look  forward  to
resolving any questions  you  may have.  Once you have reviewed this letter and
the corresponding amendment to  the  Form  8-K to be filed here shortly, please
let us know if you have further questions.



Date: May 7, 2013

By: /s/ Jason F. Griffith
--------------------------
Jason F. Griffith
Its:Chief Executive Officer, Chief Financial Officer and Director