[POGO PRODUCING COMPANY LETTERHEAD]
November 30, 2005
via facsimile and EDGAR
Mr. Barry Stem
Senior Assistant Chief Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
Washington D.C. 20549-7010
Re: | Pogo Producing Company |
| Mr. Barry Stem’s November 16, 2004 comment letter on the Annual Report on Form 10-K for the Year Ended December 31, 2004 (File No. 1-7792). |
Dear Mr. Stem:
Pogo Producing Company, in accordance with the above referenced letter, hereby notifies you that it expects to provide a response to the staff’s comment by Thursday, December 15, 2005. The company wishes to use this additional time to research and formulate a thorough response.
| Sincerely, |
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| /s/ Michael J. Killelea |
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| Senior Vice President, |
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| General Counsel and |
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| Corporate Secretary |
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