Vaughan Foods CORRESP Correspondence with SEC

VAUGHAN FOODS, INC.
216 N.E. 12^TH STREET
MOORE, OK 73160

June 25, 2007

Via Facsimile Transmission and Edgar
Jason Wynn, Esq.
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 7010
Washington, DC 20549

Re:	Vaughan Foods, Inc. (the “Company”)
	Registration Statement on Form S-1
	Filed October 6, 2006
	File No. 333-137861

Mr. Wynn:

     In connection with the proposed public offering of 2,150,000 Units by the Company, under the above referenced Registration Statement on Form S-1 (the “Filing”), the Company hereby requests pursuant to Rule 461(a) under the Rules and Regulations promulgated under the Securities Act of 1933, as amended, that its Registration Statement become effective at 4:15 p.m. Eastern Time, on June 27, 2007, or as soon thereafter as practicable. Simultaneously therewith, the Company requests effectiveness of its Registration Statement under the Securities & Exchange Act of 1934 on Form 8-A.

     With respect to this request the Company acknowledges that:

• Should the Commission or the staff, acting pursuant to delegated authority, declare the Filingeffective, it does not foreclose the Commission from taking any action with respect to the Filing;
• The action of the Commission or the staff, acting pursuant to delegated authority, in declaring theFiling effective does not relieve the Company from its full responsibility for the adequacy andaccuracy of the disclosure in the Filing; and
• The Company may not assert staff comments and the declaration of effectiveness as a defense inany proceeding initiated by the Commission or any person under the federal securities laws of theUnited States.

Very truly yours,
Vaughan Foods, Inc.
By:	/s/ MARK E. VAUGHAN
	Mark Vaughan
	Chief Executive Officer