| Re: | United States Natural Gas Fund, LP Form 10-K for the year ended December 31, 2008 Filed on March 2, 2009 File No. 001-33096 |
| 1. | We note your response to comment 2 in our letter dated September 29, 2009; however, we continue to believe that your portfolio composition is material to an investor’s understanding of the fund’s business. It appears that disclosing your portfolio composition in percentage terms rather than dollar amounts could provide the appropriate information and avoid the concerns expressed in your response regarding volatility in the size of the fund. Disclosure of your portfolio holdings as of the end of each quarter in the fiscal year may address concerns about the limited nature of year-end only disclosure. In addition, we note that such disclosure would appear to be consistent with your financial statement disclosure requirements. Please confirm that you will provide disclosure about your portfolio as previously requested or, alternatively, provide a more detailed analysis regarding the materiality of this disclosure. |
| Response: USNG confirms that it will include disclosure in its quarterly and annual reports on Form 10-Q and 10-K, as the case may be, consistent with your request. Specifically, USNG will include the following disclosure in the section entitled, “Management’s Discussion and Analysis of Financial Condition and Results of Operations”: |
| To the extent USNG holds other natural gas-related interests, other than those noted above, it will disclose these holdings in a similar manner. |
| UNITED STATES HEATING OIL FUND, LP | ||||
| By: United States Commodity Funds LLC, its general partner | ||||
| By: | /s/ Howard Mah | |||
| Name: | Howard Mah | |||
| Title: | Chief Financial Officer | |||
| cc: | James M. Cain, Esq. W. Thomas Conner, Esq. |
