Chord Energy (WLLBW) CORRESP Correspondence with SEC

Whiting USA Trust I	Whiting Petroleum Corporation
919 Congress Avenue, Suite 500	1700 Broadway, Suite 2300
Austin, Texas 78701	Denver, Colorado 80290-2300
(512) 236-6599	(303) 837-1661

April 21, 2008

Via EDGAR

Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention: Laura Nicholson

Re:	Whiting USA Trust I and Whiting Petroleum Corporation —
	Registration Statement on Form S-1 / Form S-3 (Registration Nos. 333-147543 and 333-147543-01)

Ladies and Gentlemen:

     Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned Registrants hereby request that the above-referenced Registration Statement be declared effective at 4:00 P.M., Eastern Time, on April 23, 2008, or as soon as is practicable thereafter.

     The Registrants acknowledge that:

• should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

• the Registrants may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours, WHITING USA TRUST I By: WHITING PETROLEUM CORPORATION
By:	/s/ Bruce R. DeBoer
	Bruce R. DeBoer
	Vice President, General Counsel and Corporate   Secretary

WHITING PETROLEUM CORPORATION
By:	/s/ Bruce R. DeBoer
	Bruce R. DeBoer
	Vice President, General Counsel and Corporate   Secretary

April 21, 2008

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549

Re:	Whiting USA Trust I
	Whiting Petroleum Corporation
	Registration Statement on Form S-1/S-3
	Registration Nos. 333-147543 and 333-147543-01

Dear Sir or Madam:

     In accordance with Rule 461 of the Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned, as Representatives of the several Underwriters, hereby join in the request of Whiting USA Trust I and Whiting Petroleum Corporation for acceleration of the effective date of the above-captioned Registration Statement so that it becomes effective on April 23, 2008 at 4:00 p.m., Washington time, or as soon thereafter as practicable.

     Pursuant to Rule 460 of the Rules and Regulations of the Commission under the Securities Act regarding the distribution of preliminary prospectuses, we hereby advise the Commission that the distribution of the Preliminary Prospectus dated April 11, 2008 (the “Preliminary Prospectus”) commenced April 14, 2008 and will continue through April 23, 2008. As of the date hereof, approximately 11,350 copies of the Preliminary Prospectus have been distributed to prospective underwriters, institutional investors, dealers and others. In addition, this will confirm that the undersigned will comply with, and that we have been informed by participating underwriters and dealers that they will comply with, Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.

     The undersigned were advised on April 7, 2008 by the Corporate Finance Department of the Financial Industry Regulatory Authority that it has reviewed the above-captioned proposed offering and that it has determined to raise no objections with respect to the fairness and reasonableness of the underwriting terms and arrangements of the offering.

By:	Raymond James & Associates
By:	/s/ Kenneth M. Nelson
Name:	Kenneth M. Nelson
Title:	Managing Director