Theodore Gazulis
Executive Vice President and
Chief Financial Officer
415.461.5025 ext 220
tgazulis@resoluteenergy.com
October 5, 2012
Via Federal Express and EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-7010
Attention: Ethan Horowitz, Branch Chief
| Re: | Resolute Energy Corporation |
Form 10-K for Year Ended December 31, 2011
Filed March 13, 2012
File No. 001-34464
Dear Mr. Horowitz:
Set forth below is the response of Resolute Energy Corporation (“we” or the “Company”) to the comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in the letter dated September 28, 2012, regarding the above-referenced filing. For the convenience of the Staff, we have transcribed the comments being addressed and the Company’s responses to each comment in sequence.
Form 10-K for Fiscal Year Ended December 31, 2011
Items 1 and 2 – Business and Properties, page 1
Estimated Net Proved Reserves, page 8
| 1. | We note your response to comment 2 in our letter dated August 29, 2012. The information provided with regard to the Aneth Unit Phase 4 CO2 flood and plant project and the McElmo Creek Unit DC IIC water and CO2 flood and plant project indicates that both will be substantially completed by the fourth quarter of 2014. Please tell us when the proved undeveloped reserves associated with these projects are expected to be converted to proved developed status. |
We anticipate that the reserves in each of these project areas will be converted to proved developed status as infrastructure related thereto is placed into service, which we expect will occur by the fourth quarter of 2014.
Resolute Energy Corporation
80 E. Sir Francis Drake Blvd., Suite 2C, Larkspur, CA 94939
Voice 415.461.5025 Fax 415.461.5045
Securities and Exchange Commission
October 5, 2012
Page 2
In responding to your comments, we acknowledge that:
| • | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| • | the Company may not assert Staff comments 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,
Resolute Energy Corporation
/s/ Theodore Gazulis
Theodore Gazulis
Chief Financial Officer