[Pogo Letterhead]
April 26, 2007
via facsimile and EDGAR
Ms. April Sifford
Mr. Ryan Milne
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.W.
Washington D.C. 20549
Re: |
| Pogo Producing Company |
|
| Letter Dated April 12, 2007 |
|
| Form 10-K for the Fiscal Year Ended December 31, 2006 |
|
| File No. 1-7792 |
Dear Ms. Sifford and Mr. Milne:
Pogo Producing Company, in accordance with the above referenced letter, hereby notifies you that it expects to provide a response to the staff’s comments by Thursday, May 10, 2007. Due to personnel constraints associated with the company’s continued pursuit of strategic alternatives, preparation of recent filings and its quarterly earnings press release, the company requires additional time to formulate a thorough response.
Respectfully, |
| |
|
|
|
|
|
|
| /s/ James P. Ulm, II |
|
|
|
|
| Senior Vice President and |
|
| Chief Financial Officer |
|
